Appendix 1.2: EIA Scoping Opinion

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)

Communities and Housing Civic Offices, Euclid Street Swindon, SN1 2JH

Tel: 01793 445503 Fax: 01793 463306 DX: 133055 Swindon 16 Minicom: 01793 436659

Donna Palmer Please ask for: Mr Edward Snook Turley Direct Dial No: 01793 466427 The Pinnacle Email: [email protected] 20 Tudor Road Our Ref: S/EIA/18/1472 Reading Date: 16th October 2018 RG1 1NH

Dear Ms Palmer,

Town and Country Planning Act 1990 Town and Country Planning (Environmental Impact Assessment) Regulation 2017

Re: Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development. At: Inlands Farm, The Marsh, Wanborough

I refer to the submission and email dated 31st August 2017 seeking a Scoping Opinion pursuant to Section 15 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017.

Whilst this is not an application for a Screening Opinion, after careful consideration of the matters contained within your submission and email dated 31st August 2018 and having regard to the relevant provisions of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, the Local Planning Authority considers that the proposed development is an EIA development as it would have a significant environmental impact. The Council concurs with your view that an EIA is required for the development.

1 Proposal

1.1 The proposal comprises the development of a science park comprising up to 32,381 sqm of Use Class B1b (research and development) floor space and 49,907 sqm of use class B1c (light manufacturing), as well as associated highway improvements, green infrastructure and drainage systems.

1.2 The application site extends to approximately 40.2 hectares and is currently in agricultural use. It is situated within the administrative boundaries of Swindon Borough Council and Wanborough Parish Council. Swindon Urban Area is located to the west of the application site, whilst the New Eastern Villages (‘NEV’) Strategic

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Allocation, brought forward through Policy NC3 of the Swindon Borough Local Plan 2026 (‘Local Plan’), is to the north. To serve the new communities at the NEV, the Southern Connector Road (‘SCR’) is currently proposed to run immediately to the west of the site.

2 Scoping Opinion

2.1 The LPA has consulted with various statutory consultees as well as other third parties and received a number of comments which have been summarised below. Full consultee responses are available on the Swindon Public Access website using the application reference number.

3 Consultee Comments

2.1 Statutory & External Consultee Comments

3.1.1 Campaign for the Protection of Rural England (CPRE)

The proposed development, for which the above Opinion is sought, conflicts with Swindon Local Plan Policy NC3 which covers development to the east of the A419 as defined on the Policies Map.

The site lies within the Indicative Non-Coalescence area of NC3 and outwith the allocated development area. The designation was established for express reasons. a) To prevent villages like Wanborough from the impact of the creeping development and to b) protect the area close to the boundary of the AONB from the cumulative effect of creeping development. There are no planning considerations which support development of this greenfield site.

Para 23 of NPPF July 2018 underlines the need to have objectively assessed land use designations and allocations identified on a policies map.

This Science Park is in reality an industrial site with some specialised manufacturing. There is no estimated number of jobs to be created. It appears to be a hybrid application of low density.

A Science and Technology centre is being developed at the former Hullavington Airfield, being brownfield this would be a more appropriate site.

3.1.2 Environment Agency

We consider the following areas necessary for inclusion within the Environmental Statement / planning submission:

 Surface Water Drainage and Flood Risk  Water Resources (supply) and Water Efficiency  Wastewater  Groundwater Protection  Impact on protected species and habitat 2

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)  Construction Environment Management Plan, including pollution prevention measures, and  Waste management

Surface Water Drainage / Flood Risk The site falls within Flood Zone 1, as shown on the Flood Map for Planning. Although the site is outside flood zones 2 and 3 it does not mean the site is free from flood risk. The Environment Agency flood maps are indicative in nature and do not show flood zones (2 & 3) associated with watercourses where the catchment size is smaller than 3 square kilometres.

The site may be at risk from other sources of flooding (e.g. groundwater, surface water), which are not considered in the mapping of flood zones. The Lead Local Flood Authority can also advise on this matter.

If the site is greater than 1 hectare, under National Planning Policy Framework, a FloodRisk Assessment (FRA) will be required to deal with surface water runoff from the site. The surface water drainage strategy should include pollution control measures. Further advice can be found on our website at: https://www.gov.uk/flood-risk-assessment-for-planning- applications Surface water matters are the remit of the Lead Local Flood Authority, therefore they should be consulted on this issue.

Water Supply and Waste Water Adequate water and wastewater infrastructure is needed to support sustainable development. National Planning Policy Framework (NPPF) identifies that a healthy water environment will also deliver multiple benefits, such as helping to enhance the natural environment generally and adapting to climate change.

The EU Water Framework Directive applies to surface waters and groundwater. It requires member states to prevent deterioration of aquatic ecosystems and protect, enhance and restore water bodies to ‘good’ status.

When drawing up wastewater treatment proposals for any development, the first presumption is to discharge foul drainage into a public sewer to be treated at a public sewage treatment works (those provided and operated by the water and sewerage companies). This should be done in consultation with the local sewerage company.

Where a connection to a public foul sewer is not feasible (in terms of cost and/or practicality) a package sewage treatment plant can be considered. This should offer treatment so that its final discharge meets the standards set by the required Environment Agency Environmental Permit A proposal for a package sewage treatment plant and infrastructure should set out clearly the responsibility and means of operation and management to ensure that the Permit is not likely to be breached during the life of the plant.

Sustainable Construction Sustainable design and construction should be implemented across the proposed development. This is important in limiting the effects of, and adapting to climate change. Running costs for occupants can also be significantly reduced.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)

Biodiversity The National Planning Policy Framework is clear that pursuing sustainable development includes moving from a net loss of biodiversity to achieving net gains for nature, and that a core principle for planning is that it should contribute to conserving and enhancing the natural environment and reducing pollution. Information on biodiversity impacts and opportunities should inform all stages of development including, for instance, site selection and design including any pre-application consultation as well as the application itself.

Groundwater Protection / Contaminated Land If historic use of the site may have caused land contamination then paragraph 109 of the NPPF states that the planning system should help prevent both new and existing development from contributing to, or being put at risk from unacceptable levels of water pollution. Thorough site investigation information must be prepared and presented by a competent person.

Further guidance on what should be contained in the investigation and issues associated with groundwater protection can be found here: https://www.gov.uk/government/collections/groundwater-protection

Pollution Prevention during Construction Safeguards should be considered for implementation during the construction phase to minimise the risks of pollution from the development. Such safeguards should cover:  the use of plant and machinery;  oils/chemicals and materials;  the use and routing of plant and vehicles;  the location and form of work and storage areas and compounds;  the control and removal of spoil and wastes. The applicant should refer to the Environment Agency's Pollution Prevention Guidelines at: https://www.gov.uk/government/collections/pollution-prevention-guidance-ppg

Waste Should this proposal be granted planning permission, then in accordance with the waste hierarchy, we wish the applicant to consider reduction, reuse and recovery of waste in preference to offsite incineration and disposal to landfill during site construction. If you require more specific guidance it is available on our website: www.environment- agency.gov.uk/subjects/waste/.

3.1.3 Highways England

Highways England (“we”) are a Statutory Consultee on Planning Applications under the Town and Country Planning (Development Management Procedure) Order 2015. In discharging this responsibility we act as a proactive partner and therefore welcome Pre- Application discussion, including the opportunity to provide advice on the scope of any Environmental Statement pursuant to the procedures set out in the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, which also identified the Highways Agency (now Highways England) as a statutory party.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) In your letter dated 3rd September 2018, you have invited Highways England to provide comments on the scope of an EIA Report in respect of the development of a Science Park comprising up to 32,381 sqm B1b Research and Development use and 49,907 sqm B1c Light Industrial use on land at Inlands Farm, Wanborough.

Highways England are liaising with the applicant regarding the scope of the Transport Assessment work required to support a subsequent planning application with particular regard to the impact the development will have on M4 J15 and the A419. This work is ongoing.

We have set out below both the general and specific areas of concerns that Highways England would wish to see considered as part of any Environmental Statement. The comments relate specifically to matters arising from Highways England’s responsibilities to manage and maintain the Strategic Road Network (SRN) in England.

Comments relating to the local road network should be sought from the appropriate Local Highway Authority.

General aspects to be addressed in all cases:  An assessment of transport related impacts of the proposal should be carried out and reported as described in the current Department for Communities and Local Government (DCLG) guidance on ‘Travel Plans, Transport Assessments and Statements in decision-taking’. Reference should be made to Highways England policy requirements set out in Circular 02/2013.  Environmental impacts arising from any disruption during construction, traffic volume, composition or routing change and transport infrastructure modification should be fully assessed and reported, along with the environmental impact of the road network upon the development itself.  Adverse changes to noise and air quality should be particularly considered, including in relation to compliance with the European air quality Limit Values and/or Local Authority designated Air Quality Management Areas (AQMAs) and World Health Organisation (WHO) criteria.  No new connections are permitted to Highways England’s drainage network. In the case of an existing ‘permitted’ connection, this can only be retained if there is no land use change.  Information relating to the flooding zone that the site is located is required and we stress that development must not lead to any surface water flooding on the SRN carriageway.  Works in the vicinity of the SRN should be scheduled to avoid coinciding with other construction projects in order to limit the level of disturbance to the network.

Location specific considerations:  Any assessment should consider the operation of the Strategic Road Network – in this case M4 J15 and the A419 carriageway; specifically any links to the network which could detrimentally affect its performance. This includes the M4 J15 / A419 and A419 / Purley Road / Pack Hill / A4259 interchanges.  Highways England should be involved in any discussions regarding use of the Swindon Borough Council traffic model in order to assess the impact of the proposed

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) development. This is to ensure that the scope of the model and model outputs will be acceptable to Highways England, before work is undertaken.  It is understood that this site is not currently allocated within the Local Plan. If the site remains unallocated, Paragraph 22 of Circular 02/2013 would apply. This states that where proposals are not consistent with the adopted Local Plan a full assessment of their impact will be necessary, which will be based on the performance and character of the Strategic Road Network as determined by the presumption that the Plan proposals will be fully implemented.  Analysis of accident data for the latest available full five-year period regarding the SRN surrounding the site should be undertaken. Any relevant collision clusters or recurring accident causation factors should be assessed and properly mitigated where the proposed scheme is shown to make conditions worse  Suitable NMU facilities should be provided. These should be fully integrated to ensure that levels of severance are not detrimental.  The potential impact of construction vehicles on the SRN should be included within the assessment work.

Advice received in relation to the scoping of additional technical notes and submissions should also be considered within the Transportation chapter of any submitted Environmental Statement.

3.1.4 Historic England

We note that the location of this project is in proximity to a number of sensitive, designated heritage assets. These include:

 The Upper Wanborough Conservation Area, located immediately to the east of the project area. The Conservation Area includes the grade I listed Church of St Andrew (National Heritage List for England ref. 1185526) and encompasses eleven other buildings listed at grade II;  The Lower Wanborough Conservation Area, located c 450m to the east of the project area. to the east of the project area. The Conservation Area encompasses eleven buildings listed at grade II. The Scheduled Monument recorded as ‘Hall Place’ (NHLE ref. 1016325) is located on the eastern edge of the settlement;  The Liddington Conservation Area, located c 1.2km to the south-east of the project area, which includes the grade I listed Church of All Saints (NHLE ref. 1299741), the grade II* listed Liddington Manor (NHLE ref. 1023399), and encompasses ten other buildings listed at grade II;  A group of grade II listed buildings located between c 150m and 400m to the north of the project area, at Wanborough Marsh and Foxbridge Farm.

The project has the potential to impact on the setting of these designated heritage assets, possibly leading to a loss of significance. This matter is referred to in paragraphs 190 and 194 of the National Planning Policy Framework. It is for the local authority to determine whether a proposed Environmental Statement is adequate. However, we have concerns with the scoping exercise already undertaken (pages 32 to 42 of the Scoping Opinion Request; Turley 2018), in particular the lack of a reference to the Lower Wanborough Conservation Area or suitable maps or figures to locate assets scoped in or out at this stage. We also note a degree of apparent confusion between the built heritage and archaeological 6

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) assets: the Hall Place Scheduled Monument (above) is referred to as part of the historic built environment.

In line with the advice in the National Planning Policy Framework (paragraph 190), we would expect any Environmental Statement to contain a thorough assessment of the likely effects which the proposed development might have upon the historic environment. In terms of detailed assessment methodology, we would expect any assessment of settings to be undertaken in accordance with our recently-published guidance (HE 2017 [rev] Good Practice Advice in Planning, Note 3, The Setting of Heritage Assets). Similarly, we would expect any over-arching EIA methodology to accord with the guidance given in Highways Agency note 20807 of 2007, commonly known as DMBRB 2.

3.1.5 Natural England

Case law and guidance has stressed the need for a full set of environmental information to be available for consideration prior to a decision being taken on whether or not to grant planning permission. Annex A (attached to the full Natural England consultee comments) provides Natural England’s advice on the scope of the Environmental Impact Assessment (EIA) for this development.

Should the proposal be amended in a way which significantly affects its impact on the natural environment then, in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, Natural England should be consulted again.

3.1.6 North Wessex Downs AONB

The AONB agrees that the proposed is EIA development and welcomes the opportunity to comment of the scoping report.

The North Wessex Downs (NWD) AONB has significant concerns and would object to any proposed development of this site.

The development conflicts with Swindon Local Plan Policy NC3 which covers development to the east of the A419, as defined on the Policies Map the site is within a Non-Coalescence area of NC3. The designation was created for a reason, which is to prevent villages like Wanborough from the impact of the creeping development and to protect the area close to the boundary of the AONB from the cumulative effect of creeping development.

Para 23 of NPPF (2018) underlines the need to have objectively assessed land use designations and allocations identified on a policies map. The Local Plan Review proposes no changes to NC3 nor the Policies Map. There are existing redundant/vacant industrial and commercial sites around Swindon that are available for development and could accommodate the uses and scale of development proposed, such as 2 adjoining sites within Dorcan Industrial estate, the former toys r us site.

The landscape assessment should also consider views to the north Wessex downs as it is part of the experience taken when using the PROW network on the edge of Swindon and not merely views from as noted in para 7.1 of the report.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Due to the potential for long distance views a 5km radius should be set rather than 2km with a couple of ad hoc locations. ZTVs would set the groundwork for an LVIA in terms of potential viewpoints.

Liddington Castle should be included and the Ridgeway national trail should also be landscape receptors (para 7.11).

Additional representative views should be included in an LVIA from the PROW south of Wanborough House with views towards the SE, the PROW to the NW of Marsh Farm with a view SE from part way between the A419 and Marsh Farm and a view N to NW from below Hill Barn adjacent to the Ridgeway (road) at the base of Liddington Hill.

Representative view 13 should include a view from Liddington castle and view 15 should include the Ridgeway National Trail and simply the Road.

Would disagree with para 15.3 in terms of the Environmental Zone classification for lighting, given its agricultural use and lack of street lights the site would be categorised under EZ1 not EZ2 as stated. Dark skies are a special quality of the AONB and this extends beyond the set boundary into the setting.

Lighting effects need to be considered against the landscape particularly the AONB and not simply to the users of local road and footpath networks.

The local wildlife site to the northern boundary does not appear to have been acknowledged within the report although it is noted that a separate ecological assessment will be carried out. A full ecological assessment should be carried out due to the proximity of the local wildlife site and Coate Water SSSI.

3.1.7 Thames Water

Thames Water are the statutory water and sewerage undertaker for the area and would like to make the following comments: The EIA Regulations 2017 set out in Schedule 4 that water and wastewater issues may need to be covered in an EIA.

Thames Water considers the following issues should be considered and covered in either the EIA or planning application submission: 1) The developments demand for Sewage Treatment and network infrastructure both on and off site and can it be met. 2) The surface water drainage requirements and flood risk of the development both on and off site and can it be met. 3) The developments demand for water supply and network infrastructure both on and off site and can it be met. 4) Build – out/ phasing details to ensure infrastructure can be delivered ahead of occupation. 5) Any piling methodology and will it adversely affect neighbouring utility services.

The developer can obtain information to support the EIA by visiting the Thames Water website (https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your- development).

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) 3.2 Internal Consultee Comments

3.2.1 Archaeological Advisor (Wiltshire Council)

This is an archaeologically sensitive area, with part of a Roman settlement complex within the western edge of the site. I would except to see an EIA with a comprehensive chapter on cultural heritage submitted with any planning application to develop this site. The Chapter will be need to include the results from a programme of archaeological evaluation to include geophysical survey and trial trenching.

3.2.2 Conservation Officer

In brief the proposals are for a ‘Science Park’ (Class B1b) and light manufacturing units (B1c) (total of over 82,000 sqm) plus associated works. I note that this is proposed to be a phased development with in part being subject to demand (EIA SOR para 3.7).

In the submitted EIA SOR the zone of investigation (study area) is stated to be 2km (EIA SOR para 8.4). I note here that in terms of the landscape considerations that the study area has been increased to 3 km to include Liddington Hill (EIA SOR Chapter 7 para 7.6) and Liddington is also referred in Chapter 9 (Archaeology) noting that “an impact on the setting of this asset may be anticipated” (EIA SOR para 9.2).

The main consideration is the effect of the proposed development upon the setting of heritage assets.

In regard to the effects of the proposed development upon setting, the methodology contained in the Historic England Guidance ‘Good Practice Advice 3 The Setting of Heritage Assets’ (GPA 3, 2nd Edition) should be utilised in demonstrating a robust consideration and assessment. This document is referred to in the EIA SOR.

To understand the likely affects the stepped approach contained in GPA 3 guides the following steps:

 Step 1: Identify which heritage assets and their settings are affected.  Step 2: Assess the degree to which these settings make a contribution to the significance of the heritage asset(s) or allow significance to be appreciated.  Step 3: Assess the effects of the proposed development, whether beneficial or harmful, on that significance or on the ability to appreciate it.  Step 4: Explore ways to maximise enhancement and avoid or minimise harm.

The proposed EIA needs to demonstrate this approach. Consideration of the effects of the proposed development upon the setting of heritage assets includes the asset’s physical surroundings as well as the experience of the asset.

There are also significant parallels with other areas of expertise and specifically I would highlight those relating to Landscape, for example the Zone of Theoretical Visibility (ZTV) study analysis.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) “A ‘Zone of Visual Influence’ defines the areas from which a development may potentially be totally or partially visible by reference to surrounding topography. However, such analysis does not take into account any landscape artefacts such as trees, woodland, or buildings, and for this reason a ‘Zone of Theoretical Visibility’ which includes these factors is to be preferred” (GPA3 p9).

Further, the effects of lighting and light spill are also referred by Landscape colleagues and this, as highlighted in GPA 3 is one of the numerous features of a proposed development that can influence and have implications regarding setting. This may offer opportunities to correlate evidence within the EIA submission.

Historic England refer to the Lower Wanborough Conservation area which is omitted from the scoped in study (although within the 2km). It would be useful to understand further the consideration of that area and any assets contained therein via the EIA.

Some of the omitted designated assets as identified at pre application are now generically included in Table 8.1 (EIA SOR Table 8.1) for example listed buildings which are also contained within Conservation Areas. I note that those for Upper Wanborough are seemingly restricted to those in ‘closer proximity’ whereas there is no seemingly comparable limitation to those in Liddington (or Lower Wanborough Conservation Area). Again the basis for consideration for those included or excluded needs to be fully evidenced.

The EIA SOR appears to refer to non-designated heritage assets and specifically to the Councils adopted SPG relating to ‘Buildings of Significant Local Interest’. The two are not comparable, not least the definition of heritage asset is broader than the SPG considers.

Further the SPG is not an exhaustive list of buildings but contains principles upon which the council may consider a building to qualify. The developer should identify any likely non- designated heritage assets and likely affects upon them. My pre application comments identified a number which maybe worthy of consideration.

Regarding the structure and format of the EIA in regard to the consideration of heritage assets. Historic England highlight this in their response and the confusion regarding archaeological assets. By way of further example Liddington Castle (a scheduled Hill Fort) is contained in table 8.1 pertaining to ‘built heritage’ (EIA SOR Chapter 8) rather than being considered under ‘Archaeology’ (EIA SOR Chapter 9). Further archaeological assets e.g. Hall Place and Stone circle are noted to be scoped out as stated in EIA SOR para 8.6. Clarity as to the consideration of assets typologies would be welcomed to avoid confusion.

In terms of the background studies to inform assessment I welcome the referral to Heritage Statements (EIA SOR par 8.10) although seek clarity of the reference in the immediately following paragraph to ‘built heritage baseline appraisal’. Clarity and overall consistency would aid the appropriate consideration of heritage assets and how relevant (HS, baseline assessments, ZTV etc) evidences and assessments are utilised to effectively inform the identified steps as noted above.

Similarly the referral in the EIA methodology (i.e. Highways Agency - DMBRB 2) is appropriate although clearly influenced by the primary consideration and assessment of potentially affected assets.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)

Overall the EIA SOR refers to the appropriate methodologies to undertaking the EIA however there is still some necessary work to demonstrate to the overall scope of the assets to be considered and how that is influenced by the sites characteristics and the proposed development.

3.2.3 Ecology Officer

Regarding this request (EIA Scoping Opinion Request, Turley, August 2018) to scope ecology out of the EIA, I am of the opinion that it should be included within the EIA. My reasons are:

1) 40ha of agricultural land will be developed. This major change of use will have ecological impacts. 2) The summary ecological information acknowledges that some protected species are present on the application site. A possible bat roost has been found in the centre of the site. Protected species are a material consideration in determining the planning application. 3) The scoping request acknowledges that the application site is 1.7km east of Coate Water Site of Special Scientific Interest and therefore falls within the Impact Risk Zone for the SSSI. The EIA will need to demonstrate that there will be no adverse impact on the SSSI. The 2018 National Planning Policy Framework says “development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted.” 4) The summary ecological information provided in the scoping request supplies insufficient information for us to be able to make our own assessment of their conclusion.

3.2.4 Environmental Health Officer (Air Quality & Noise)

The scope of the proposed EIA looks suitable to cover our concerns. The primary concerns are as follows:

Noise during the construction phase, especially from haul routes in/out of the site. I would be concerned if the current trackway serving Inlands Farm was used as the primary haul route, as this would result in all construction traffic passing a noise sensitive receptor on the quiet north west border of the proposed development.

Noise during the operational phase from plant equipment and vehicle traffic on site, a robust BS 4142:2014 assessment should identify any potential issues at this stage. Where the rating level of any noise source exceeds 5dB below the background level (LA90), as determined by a BS 4142:2014 assessment, details of noise mitigation would be expected.

Concerns surrounding dust and air quality will be answered in the construction environmental management plan.

The final, and perhaps biggest concern is the risk of a perceived loss of amenity for Wanborough residents because the development will inevitably impact upon the existing

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) night-time scene between Wanborough and the A419/Swindon, as well as the potential for light intrusion at nearby sensitive receptor properties.

To summarise, I support the proposals made about the scope of the Environmental Impact Assessment.

3.2.5 Environmental Health Officer (Contaminated Land)

I can confirm that the scope of work proposed within the scoping document is acceptable, in view of the apparent agricultural land use history of the proposed development site.

3.2.6 Landscape Officer

Study Area I’m unsure how the study area has been identified without first undertaking a computer generated Zone of Theoretical Visibility (ZTV) study, which would be expected for an application of this scale.

We consider this a more robust approach, and one we request. I’m concerned that no mention is made of this approach in 7.6 ‘Study Area’. Instead what appears to be a subjective statement by the author of what is ‘considered an appropriate area of study’ is made. This is not acceptable without an evidence based approach to support it.

For this reason, and pending the results of a ZTV study to define the study area, I’m not prepared to accept at this stage the observations and descriptions afforded to the ‘Insignificant effects’ (7.7/10), ‘Identification of Sensitive Receptors (Landscape and Visual)’ (7.11), and ‘Likely Significant Effects’ (7.12).

I understand the reasons for their inclusion, but these are predicated on a study area that has not been subject to ZTV study. My concern is reinforced by the perfectly circular ‘Principal Study Area’ and smoothly elliptical ‘Extended Study Area’ demonstrated by Appendix 3 ‘Landscape and Visual Impact Study Area’ (Drawing ‘Figure 1 - Landscape and Visual Impact Study Area’ Drawing No. COWR3001_01).

These geometric study area boundaries depicted in this drawing (without any apparent supporting evidence) do not appear to accurately reflect the ‘real world’ visibility of a study area supporting an application of this type and scale.

Conclusion: The study area needs to be informed by a robust ZTV study, not a subjective one without apparent evidence basis, as appears to have been proposed. Pending receipt of this, the effects and receptors as described in the ESSR (7.7/10, 7.11, 7.12) are not accepted. A ZTV study is required with these parameters reconsidered/amended/added to, as appropriate in response.

Proposed grading of significant effects Paragraph 7.13 of the ESSR sets out the potential for identified effects to be considered ‘beneficial’ ‘adverse’ or ‘neutral’. I’m not sure this is helpful. These ‘good’ ‘middling’ ‘bad’ parameters are not supported by the guidance as set out in GLVIA3. The author will be aware that when distinctions between levels of significance are required, the four-point

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) word scale that is accepted in 3.34 of GLVIA3 is ‘major/moderate/minor/negligible’. I would expect this standardised approach to be accommodated in any ESSR / subsequent ES.

Conclusion: The study area needs to reflect identified effects in line with accepted GLVIA terminology.

Lighting Paragraph 15.9 says that sky glow will not be assessed as ‘it is the assumption that all lighting installations will be designed to best practice guidance (Commission Internationale De L’Eclairage (1997) 126: Guidelines for Minimising Sky Glow)’.

15.9 goes on to set out that this guidance ‘includes the requirement to minimise the upwards emission of light and contribution towards sky glow.’ I note minimisation - not removal of this effect. This suggests that there is a likelihood that the effect will occur, and that there is only an assumption that design responses to minimise this effect will follow this guidance.

This presents the question, what would the effect of sky glow be if this guidance is followed, and what if it is not?

The PDS is placed unequivocally within the setting of the AONB, and the increased scrutiny this proximity demands - a point reflected in point 7.4 of the ESSR. Swindon’s Local Plan Policy EN5 C also sets out that ‘Proposals outside the AONB should not adversely affect its setting’.

Whilst the issue of the AONB’s ‘setting’ has consequences for the development as a whole (as per previous comments), it is in this context I request that sky glow is included for assessment, not excluded.

I’m concerned that this 1997 guidance might not be the most up to date available, and that the ILP’s ‘Guidance for the reduction of obtrusive light’ 2012 (for example) may hold additional/more current guidance.

Conclusion: The effect of sky glow needs to be properly assessed, not discounted. This needs to be presented for inclusion in Table 15.1: Likely Significant Effects. The findings of the requested ZTV study needs to be accommodated in 15.10 ‘Identification of Sensitive Receptors’.

Arboriculture Hedgerows and trees have been identified as a Sensitive Receptors present on site (ESSR 7.11) Comments made previously (24.04.18) still stand, included here for info:

‘Additional work to ensure preservation of trees identified as providing ‘Moderate’ potential bat shelter, as illustrated in the ‘Phase 1 Bat Scoping Survey Plan’ drawing 832.1/03 is required. It is not possible to work out with certainty where these trees are located, so they need to be individually identified on the Masterplan. We would also require a Tree survey to BS5837:2012, incorporating an Arboricultural Impact Assessment (AIA), to understand the existing context, drawing 832.1/01 (‘Phase 1 Habitat Survey Results Plan’). This drawing depicting ‘scattered mature trees’ and ‘intact species rich hedgerow’ is not sufficient.’

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)

As per these comments, a Tree survey to BS5837:2012, incorporating an Arboricultural Impact Assessment (AIA) must be undertaken as a minimum, which we would anticipate being incorporated into the baseline studies as part of the LVIA process.

The majority of hedgerows on this site would be deemed likely important and/or significant and would qualify for protection under the Hedgerow Regulations 1972, and so should be subject to full Hedgerow survey referencing the Hedgerow Evaluation and Grading Systems (HEGS).

Biodiversity As far as I can see the biodiversity report as mentioned in Table 5.1 of the Turley SOR document (August 2018) has not been submitted – we request this.

The response from Natural England sets outs the parameters for an appropriate ecological assessment which should be followed.

3.2.7 Lead Local Flood Authority (LLFA)

A flood Risk Assessment (FRA) and/or Drainage Strategy (DS) will need to be submitted with any outline or full application in relation to this site. The FRA/DS should demonstrate the following:

 That proposed flows from the site will discharge at or below greenfield runoff rates, or as close as practical for any areas that have been previously developed;  The impact upon the existing drainage systems is mitigated by discharging the flow throughout the management train rather than relying upon a single point of discharge;  SuDS Source Control measures to manage water quantity and maintain water quality have been implemented wherever possible and through the management train so the development is not reliant upon large attenuation features close to the points of discharge;  Proposed SuDS have been selected to provide a wide range of benefits including amenity, biodiversity and maintaining water quality;  During construction, adequate measures are proposed to control pollution to existing watercourses and groundwater;  Surface water can be safely managed within the proposed development, up to and including a 1 in 100 year plus climate change event;  Proposed and existing drainage features on the site will be maintained and managed after completion with confirmation from the relevant authority that they will adopt any systems that are being offered for adoption;  Confirmation that the applicant has consent for any outfalls from the proposed drainage systems into a public sewer or other drainage system not owned by the applicant;  The strategy mimics the existing drainage characteristics of the site by retaining and utilising any existing drainage features;  If any existing drainage features such as existing watercourses (including ditches) are proposed to be removed or culverted, these details are agreed with the LLFA by obtaining Land Drainage Consent or the Environment Agency for main rivers; 14

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)  Groundwater monitoring is undertaken for a minimum of 6 months during the winter months.

3.2.8 Local Highway Authority (LHA)

I have assessed the trip generation and traffic distribution submission and have the following comments; please be aware that these comment present no case in favour of the development and do not prejudice the eventual planning submission.

1. Data from the existing Wasdale plant and warehousing should be submitted as recorded trip survey data and parking accumulation data. The use of the submitted data included in the report is advised at risk, but can be used in advance of a sensitivity study to be submitted with the TA. 2. Delivery data will also be required to advise the development of the masterplan and appropriate service areas etc. 3. The increase in car mode share to 90% is supported, however we would welcome the calcs on the car occupancy increase. 4. We would welcome attachment of the Commonhead MCC data onto the TA. 5. The A419 mainline flows are also required and an analysis of slip road design in light of any proposed changes to the Commonhead Junction operation. 6. The ‘worst case’ trip assessment of phase 2a (para 2.4.4) is supported, as guarantees of NEV delivery, and PT increase as a result, cannot be given. 7. Phase 2b is not assessed against an average trip rate from TVSP and BBSP, as asserted in 2.6.8, as BBSP has two separate scenarios. It is suggested that BBSP scenario 2 and TVSP are used to form the average, as they closely align. 8. SBC would welcome assessments for both the AM pre peak hour and the normal peak hours. The pre-peak hours may represent the highest AM impact and flow, but members and residents will also scrutinise the standard peak. 9. The reduction in trip attraction to the Town Centre is supported, however we query whether Swindon Outskirts attraction should also be reduced. 10. The impact of NEV should be considered as a ‘committed development’ within the Saturn scenarios. In this regard, the No Nev scenario including Phase 2 cannot include the revised distribution profile accommodating 2.7% from the NEV. 11. The modelling scenarios should include the 2021 phase 1 with committed development. This is represented as the 2021 reference case, incorporating elements of NEV being delivered as part of the ‘uncertainty log’. 12. Phase 2a and 2b will need to be modelled for a 2036 year, unless a 2026 model is to be developed at a cost to the developer. 2036 was chosen for the forecast year by SBc to reflect the Local Plan Review period and a year 15 years hence from the infrastructure opening year.

Advice received in relation to the scoping of additional technical notes and submissions should also be considered within the Transportation chapter of any submitted Environmental Statement.

3.2.9 Rights of Way Officer The application in para 7.3 of the Scoping Opinion Request document has generally identified the public rights of way that cross the application site. If the site is developed those routes will need to be considered within any development along with their

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) connections outside of the site. Alternative routes along footways adjacent to roads are not acceptable and existing routes maintained through green corridors are preferable whenever possible.

The routes can be diverted by the Council under section 257 Town and Country Planning Act 1990. Further details on this can be found in the full comments. The public use of the routes must be managed by any developer during the construction of the development. The routes can be closed by temporary legal orders for up to 6 months by the Council but the costs of such orders are met by the applicant.

3.3 Adjacent Authority and Parish Council Comments

3.3.1 Oxfordshire County Council

Although the site is some way south of the A420, Oxfordshire County Council would be interested if this proposal proceeds. The scoping opinion should indicate that there is a need for a full Transport Assessment which addresses all relevant matters including Oxfordshire roads.

3.3.2 Wanborough Parish Council

Wanborough Parish Council have reviewed the above document and request that the following points are included with EIA:- 1. Section 7 – Landscape and Visual Impact a) Point 7.6 – Study Area – 2km is not a sufficient study area, due to the landscape and topology of the village this area can be viewed from afar, areas such as The Hollow, Upper Wanborough, which are more the 2km away from the site. Parish Council would like to a larger study area included. b) Point 7.9 states that there will be an insignificant visual impact to the eastern area of Wanborough. Parish Council do not agree with this statement and feel that this area should also be included within the assessment c) Point 7.11 Parish Council would like the following additions to the areas to be considered:-  Open Spaces – Church Meadow (off Lynch Field)  Roads – Purley Road, Church Road  Footpath – From St Andrews Church to Ham Road,

2. Section 8 – Built Heritage a) Point 8.8. Parish Council would like the following additions to the areas to be considered:-  Lower Wanborough Conservation Area, located to the east of the project, which includes 11 listed buildings;  Great Moorleaze Farm, The Marsh;  A group of Grade II listed buildings at Wanborough The Marsh up to Foxbridge Farm;

3. Section 9 – Archaeology a) Point 9.1 states the area is “devoid of archaeological interest”. However SBC confirmed that there is significant archaeology within and around the area as part of 16

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) the Southern Connector Road surveys taken place. A copy of the map below shows an area marked in red “significant archaeology” remains of a roman building complex. This is an extremely archaeological sensitive site and therefore a detailed assessment of the site and surrounding area should be carried out and not just a desk based assessment.

4. Section 11 – Water resources a) Section 11.4 states low ground water levels during a three month survey period from March 2018. This is not a true indicator of the ground water levels when the survey was carried out during one of the driest periods known. Parish Council would like the ground water levels surveyed in a more realistic period of time and also during the winter months. b) Section 11.7 states that there is a “very low risk of flooding” within the site and area. Parish Council have extensive evidence of flooding within the area, it is not a “very low” risk area and flooding is a serious problem. It is important that extensive surveys are carried out to ensure flooding is not increased for residents within The Marsh and surrounding area.

5. Section 12 – Transportation a) In addition to the transport roads and networks mentioned within this report, Parish Council would like the following added:-  Wanborough Road (from Covingham) up to Foxhill;  Roads within Wanborough village, High Street, Church Road up to Callas Hill crossroads;  White Hart Junction;  A420 from White Hart towards Acorn Bridges. 6. Other points a) There is no mention about the protected route of the canal as part of SBC’s Local Plan for the NEV. This needs to be included as part of the EIA.

This site is a Greenfield site within open countryside, within close proximity to a number of sensitive designated heritage assets. It is important that a detailed assessment is carried out on site and not just a desk based survey for all areas within the EIA.

3.3.3 Bishopstone Parish Council

Councillors endorse Wanborough Parish Council’s objections and object in principle on the basis that the land is protected as a Non Coalescence Area in the adopted Local Plan where land between the NEV and Wanborough shall remain as open countryside.

3.4 Third Party Comments

3.4.1 Wilts & Berks Canal Trust (W&BCT)

It is noted that the scoping document makes no mention of the Wilts & Berks Canal. The indicative line of the canal passes through the site and is protected by Local Plan Policy EN11 – Heritage Transport.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) It is understood from conversation with the applicant’s agent at the public consultation held at the Coate Holiday Inn on 5th September 2018 and their website that the canal is recognised to the extent that an alternative route will be proposed to reduce impact on the development. This alternative deflects the canal to the West to cut through only the southwest corner of the Inlands Farm. This may be workable locally but will fail to be adequate as a through route if it proves impossible to take the canal close to the Southern Connector Road and away from the development in the northwest corner of Inlands Farm. Roman remains have recently been discovered there which may block the canal route and also impact on the proposed development.

The Trust is currently reviewing the route for the canal from the crossing of B4192 Purley Road to the crossing of Wanborough Road but is presently dependent on receiving more information on the new alignment of the Southern Connector Road and the constraints imposed by the Roman remains. It may be necessary to direct the canal route through the Inlands Farm as originally proposed. Close co-operation between all three projects is essential to ensure that all achieve a satisfactory result.

As regards the Scoping Opinion Request, the effect of the canal and its construction should be considered within the listed studies. The canal is a relevant development within the meaning of paragraph 5.1 of the scoping request and the Environmental Statement should “identify and evaluate the likely significant environmental effects arising from the Proposed Development both in its own right and in combination with other relevant developments”.

The canal should be added to the list of relevant developments in paragraph 5.51.

In defining possible mitigation works the EIA should consider the benefits brought by the canal such as pedestrian and bicycle routes along the towpath, surface water management and flood mitigation options, and improved diversity of the environment for wildlife.

3.4.2 Residents

Six residents have commented on the Scoping Application. The key points raised are summarised below:

 There is no mention of the proposed canal route, which should be protected in accord with Policies NC3 and EN10 of the Local Plan.  Infrastructure proposed as part of the NEV is already planned, additional development would put further pressure on this, particularly the highway network.  Existing brownfield sites and/or allocated employment should be used before greenfield land is used.  The addition the Science Park will result in increased noise and traffic in the area, particularly rat-running through nearby villages.  The proposed development would degrade the character of Wanborough village, and have an adverse impact on the North Wessex Downs AONB.  The proposal does not consider the revised arrangements of the Southern Connector Road (SCR) or the effect of existing and future traffic flows. The surrounding network should remain as countryside lanes.  The application does not appropriate consider the archaeological features at the site.

EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472)  The additional requirements for the utilities to serve the site will cause further harm to the countryside.  The proposal would end up being an industrial site, resulting in a well-lit environment bringing noise and disruption to the area.  A large amount of space will be required for associated activities such as car parking.  The large building and surrounding hardstanding will change the flood plain and potentially result in flooding issues elsewhere.  The areas of the study should be widened to include the impact on a much wider geographic area, in terms of the environmental impact, traffic impact and visual impact.

4 Cumulative Effects

4.1 The Environmental Statement must fully consider and address all implications arising from the proposed scheme, particularly in relation to those which would have a wider impact on the NEV and surrounding settlements. An impact assessment to identify, describe and evaluate the effects that are likely to result from the proposed development, should also be included to ensure the all potential cumulative effects have been assessed thoroughly.

5 Summary

5.1 In reference to the chapters proposed for the Environmental Statement, the Council broadly agree with recommendations outlined within the ‘EIA: Scoping Opinion Request’ (August 2018). Notwithstanding this, the Council disagree with the proposals to scope out Ecology, and therefore recommend that Ecology be fully assessed through the EIA process, and form part of any submitted Environmental Statement. As such, the Council expect any submitted Environmental Statement to include the following matters: Socio-Economics; Landscape and Visual Impact; Built Heritage; Archaeology; Geology and Soils; Water Resources; Transportation; Air Quality; Noise and Vibration; Lighting; Waste; Climate Change; and Ecology.

5.2 Policies NC3 and EN10 seek to protect and safeguard the route alignment of the Wilts and Berks Canal. On the basis this indicative alignment runs through the site, further consideration should be given to this as part of any submission.

5.3 The Environmental Statement should demonstrate how the consultee comments outlined above, particularly relating to the methodology of assessments, have been included; unless appropriate justification and evidence is submitted outlining the reasons as to why an alternative approach has been taken.

Yours sincerely

Edward Snook

Edward Snook Senior Planner – Strategic Allocations and New Eastern Villages Team

From:SBC Development Control Sent:4 Sep 2018 12:36:46 +0100 To:Scanning;Validation Cc:Edward Snook Subject:FW: 3rd Party Planning Application - S/EIA/18/1472

-----Original Message----- From: [email protected] [mailto:[email protected]] Sent: 04 September 2018 12:04 To: SBC Development Control Subject: 3rd Party Planning Application - S/EIA/18/1472

Swindon Borough Council Our DTS Ref: 53825 4th Floor Wat Tyler House Your Ref: S/EIA/18/1472 Beckhampton Street Swindon Wiltshire SN1 2JH

4 September 2018

Dear Sir/Madam

Re: Inlands Farm, The Marsh, Wanborough, Swindon, SN4 0AS

Waste Comments

Water Comments Thank you for giving Thames Water the opportunity to comment on the above application. Thames Water are the statutory water and sewerage undertaker for the area and would like to make the following comments: The EIA Regulations 2017 set out in Schedule 4 that water and wastewater issues may need to be covered in an EIA. Thames Water considers the following issues should be considered and covered in either the EIA or planning application submission: 1. The developments demand for Sewage Treatment and network infrastructure both on and off site and can it be met. 2. The surface water drainage requirements and flood risk of the development both on and off site and can it be met. 3. The developments demand for water supply and network infrastructure both on and off site and can it be met. 4. Build – out/ phasing details to ensure infrastructure can be delivered ahead of occupation. 5. Any piling methodology and will it adversely affect neighbouring utility services. The developer can obtain information to support the EIA by visiting the Thames Water website https://developers.thameswater.co.uk/Developing-a-large-site/Planning- your-development

Yours faithfully Development Planning Department

Development Planning, Thames Water, Maple Lodge STW, Denham Way, Rickmansworth, WD3 9SQ Tel:020 3577 9998 Email: [email protected]

This is an automated email, please do not reply to the sender. If you wish to reply to this email, send to [email protected] WILTS & BERKS CANAL TRUST PATRON: HRH THE DUCHESS OF CORNWALL RESTORING IN PARTNERSHIP THE WILTS & BERKS CANAL THROUGH WILTSHIRE, SWINDON AND OXFORDSHIRE

By Email Planning Department Wat Tyler House Beckhampton Street Swindon SN12JH

20th September 2018

Dear Sirs,

Response to Consultation S/EIA/18/1472, Inlands Farm, The Marsh, Wanborough

The Wilts & Berks Canal Trust has the following comments on the Request for a Scoping Opinion on the proposed Environmental Impact Assessment for development of a Science Park at Inlands Farm.

It is understood from conversation with the applicant’s agent at the public consultation held at the Coate Holiday Inn on 5th September 2018 and their website that the canal is recognised to the extent that an alternative route will be proposed to reduce impact on the development. This alternative deflects the canal to the West to cut through only the southwest corner of the Inlands Farm. This may be workable locally but will fail to be adequate as a through route if it proves impossible to take the canal close to the Southern Connector Road and away from the development in the northwest corner of Inlands Farm. Roman remains have recently been discovered there which may block the canal route and also impact on the proposed development.

As regards the Scoping Opinion Request, the effect of the canal and its construction should be considered within the listed studies. The canal is a relevant development within the meaning of paragraph 5.1 of the scoping request and the Environmental Wilts & Berks Canal Trust: A Non-Profit-Distributing Company Limited by Guarantee. Registered in England and Wales No. 2267719 Registered Address: Dauntsey Lock Canal Centre, Dauntsey Lock, Dauntsey, Wilts. SN15 4HD Registered Charity No: 299595 Telephone: 0845 226 8567 E-mail: [email protected] Web Site: www.wbct.org.uk WILTS & BERKS CANAL TRUST 2

Statement should “identify and evaluate the likely significant environmental effects arising from the Proposed Development both in its own right and in combination with other relevant developments”.

The canal should be added to the list of relevant developments in paragraph 5.51.

Yours Faithfully

Rod Hacker Chairman, Swindon Branch, WBCT Wanborough Parish Council 15 Springlines Wanborough SN4 0ES e-mail: [email protected]

25th September 2018 Mr E Snook Swindon Borough Council Planning Department

Dear Ed Re: S/EIA/18/1472 - Inlands Farm The Marsh - Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development.

Wanborough Parish Council have reviewed the above document and request that the following points are included with EIA:-

1. Section 7 – Landscape and Visual Impact a. Point 7.6 – Study Area – 2km is not a sufficient study area, due to the landscape and topology of the village this area can be viewed from afar, areas such as The Hollow, Upper Wanborough, which are more the 2km away from the site. Parish Council would like to a larger study area included. b. Point 7.9 states that there will be an insignificant visual impact to the eastern area of Wanborough. Parish Council do not agree with this statement and feel that this area should also be included within the assessment c. Point 7.11 Parish Council would like the following additions to the areas to be considered:-  Open Spaces – Church Meadow (off Lynch Field)  Roads – Purley Road, Church Road  Footpath – From St Andrews Church to Ham Road, 2. Section 8 – Built Heritage a. Point 8.8. Parish Council would like the following additions to the areas to be considered:-  Lower Wanborough Conservation Area, located to the east of the project, which includes 11 listed buildings  Great Moorleaze Farm, The Marsh  A group of Grade II listed buildings at Wanborough The Marsh up to Foxbridge Farm

3. Section 9 – Archaeology a. Point 9.1 states the area is “devoid of archaeological interest”. However SBC confirmed that there is significant archaeology within and around the area as part of the Southern Connector Road surveys taken place. A copy of the map below shows an area marked in red “significant archaeology” remains of a roman building complex. This is an extremely archaeological sensitive site and therefore a detailed assessment of the site and surrounding area should be carried out and not just a desk based assessment.

Wanborough Parish Council 4. Section 11 – Water resources a. Section 11.4 states low ground water levels during a three month survey period from March 2018. This is not a true indicator of the ground water levels when the survey was carried out during one of the driest periods known. Parish Council would like the ground water levels surveyed in a more realistic period of time and also during the winter months. b. Section 11.7 states that there is a “very low risk of flooding” within the site and area. Parish Council have extensive evidence of flooding within the area, it is not a “very low” risk area and flooding is a serious problem. It is important that extensive surveys are carried out to ensure flooding is not increased for residents within The Marsh and surrounding area. 5. Section 12 – Transportation a. In addition to the transport roads and networks mentioned within this report, Parish Council would like the following added:-  Wanborough Road (from Covingham) up to Foxhill  Roads within Wanborough village, High Street, Church Road up to Callas Hill crossroads.  White Hart Junction  A420 from White Hart towards Acorn Bridges 6. Other points a. There is no mention about the protected route of the canal as part of SBC’s Local Plan for the NEV. This needs to be included as part of the EIA.

Yours Sincerely

Angela Raymond Clerk to Wanborough Parish Council

From:SBC Development Control Sent:14 Sep 2018 08:48:43 +0100 To:Scanning;Validation Cc:Edward Snook Subject:FW: S/EIA/18/1472 - Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development, Inlands Farm, The Marsh, Wanborough

From: Martin Fry Sent: 13 September 2018 17:02 To: SBC Development Control Subject: S/EIA/18/1472 - Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development, Inlands Farm, The Marsh, Wanborough

Dear Sirs

Thank you for consulting me on the above proposal.

The application in para 7.3 of the Scoping Opinion Request document has generally identified the public rights of way that cross the application site. If the site is developed those routes will need to be considered within any development along with their connections outside of the site. Alternative routes along footways adjacent to roads are not acceptable and existing routes maintained through green corridors are preferable whenever possible.

The routes can be diverted by the Council under section 257 Town and Country Planning Act 1990 but the applicant for such an order will need to pay for the legal orders and provide and construct a suitable alternative route to the Council’s requirements. Such legal orders can attract objections which if sustained would have to be forwarded to the Secretary of State for determination. That process can dramatically lengthen the time for completing the order process from approx 6 months to 2 years or more. It is therefore recommended that a plan of the future path network is developed at an early stage with the Council’s Rights of Way Manager and any legal orders applied for as soon as possible.

The public use of the routes must be managed by any developer during the construction of the development. The routes can be closed by temporary legal orders for upto 6 months by the Council but the costs of such orders are met by the applicant.

Regards

Martin

Martin Fry

Rights of Way and Highway Information Manager

Highways & Transport Service Delivery Swindon Borough Council

Tel: 01793 466382 Mob: 07740037450 www.swindon.gov.uk

From:SBC Development Control Sent:12 Sep 2018 09:24:19 +0100 To:Scanning;Validation Cc:Edward Snook Subject:FW: S/EIA/18/1472

From: Hughes, Lynette - Communities [mailto:[email protected]] Sent: 12 September 2018 09:22 To: SBC Development Control Cc: Planning Consultations - E&E ; [email protected] Subject: S/EIA/18/1472

Re: Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development.

At: Inlands Farm, The Marsh, Wanborough

http://pa1.swindon.gov.uk/publicaccess/applicationDetails.do?activeTab=summary&key Val=PEBMLLPT0FL00

Comments from Oxfordshire County Council

This is a scoping opinion request for a hybrid planning application for the development of land at Inlands Farm, Swindon. The proposal is a science park - up to 32,381 sqm of Use Class B1b (research and development) floor space and 49,907 sqm of use class B1c (light manufacturing), as well as associated highway improvements, green infrastructure and drainage systems.

The site extends to approximately 40.2 hectares and comprises a number of agricultural field parcels. It is situated approximately 300m to the south of the New Eastern Villages Strategic Allocation (as identified in the adopted Swindon Borough Local Plan 2026 (2015)). The site lies outside of the Swindon Urban Area Boundary and is not presently allocated for development. The North Wessex Downs AONB adjoins the southern boundary of the site.

Best regards

Lynette Hughes

Senior Planner / Strategic Planning Team / Infrastructure Strategy & Policy /

Planning & Place / Communities / Oxfordshire County Council / County Hall, New Road, Oxford, OX1 1ND /

https://www.oxfordshire.gov.uk/

Tel: 0792 0084 360

This email, including attachments, may contain confidential information. If you have received it in error, please notify the sender by reply and delete it immediately. Views expressed by the sender may not be those of Oxfordshire County Council. Council emails are subject to the Freedom of Information Act 2000. email disclaimer. For information about how Oxfordshire County Council manages your personal information please see our Privacy Notice. From:Scanning Sent:25 Sep 2018 08:10:20 +0100 To:Scanning Subject:FW: Wasdell Science Park objection

I wish to register my objection to the proposed ‘Science Park’ by Wasdell Properties Ltd at Inlands Farm, Wanborough.

I state ‘Science Park’, although it’s obvious this is just ‘PR speak’ for an Industrial Park. Wasdell are not a science group. They are a contract packaging fulfilment company, packaging and distributing for pharmaceutical companies, working shifts 24 hours a day, seven days a week in a well-lit environment, using low paid shift workers, which would bring noise and disruption to what is still a relatively peaceful village. The very nature of this type of work would mean trucks and containers accessing the site 24/7.

As well as this disruption, the site borders on an Area of Outstanding Natural Beauty (ANOB). The entrance and access to the site is within the AONB – a nationally protected area. Surely, the reason for such areas, is to preserve nature and not vandalise it? Can someone please confirm that it is the Borough’s responsibility to preserve this status?

The potential site would be over 95 acres (a larger area than the centre of the village it would blight) and although the footprint of the buildings is planned to be ‘just 14 acres’, with the provision of landscaping, footpaths and cycle-ways etc, no-one has mentioned the space for the number of car parking spaces for the 1200 plus workers. We have been informed that landscaping will take place and nature will be considered, but we already have a good natural habitat, foot paths and quiet roads that I often cycle down. The reason for newly built cycle paths as compensation for newly built roads is a nonsense. Our country roads are already quiet enough to cycle on.

With the approval of the Eastern Village Development already causing heavier traffic within our once quiet village, we will undoubtedly experience more rat-running of commuter vehicles, as well as commercial transport, which will cause bottle necks on the narrow roads in and out of the village.

Finally, the proposed area, sits on a flood plain, and there is already a fine line between flooding and not. With the building of such a large area of concrete, this will no doubt change the flood plain to the detriment of local housing.

I hope you will consider this objection along with the countless others I am sure you will receive, with this being such a controversial proposal...

CG From:Scanning Sent:25 Sep 2018 08:12:58 +0100 To:Scanning Subject:FW: Inlands Farm S/EIA/18/1472

I understand that at this stage comments are accepted on the EIA. I will object formally to a planning application should it be submitted.

The Scoping document pays scant regard to the neighbouring AONB. The EIA must take greater notice of the impact on the AONB. This should include a detailed examination of the AONB boundary, which according to online mapping is to the north not the south of Pack Hill, thus some of the PDS may actually lie in the AONB.

Those undertaking the assessment should be forced to consult more widely with the likes of CPRE, NWDAONB, W&B Canal Trust etc. Currently those proposing the development seem to be setting and marking their own homework, with an obvious conflict of interest.

The areas of the study should be widened to include the impact on a much wider geographic area, in terms of the environmental impact, traffic impact and visual impact.

Regards

Simon James SN4 0BZ

Our ref: DP.SW. AV Brunel House (Area 2) Your ref: 7143-WSP-MP-ZZ-RP-TP-010 930 Hempton Court Aztec West BS32 4SR

Direct Line: 0300 4700789

10 October 2018

Robert Rossiter Swindon Borough Council

Dear Robert,

RE: M4 / A419 – SWINDON SCIENCE PARK, LOWER WANBOROUGH

I am writing following the receipt of a Technical Note (TN), prepared by WSP on behalf of Wasdell Properties Ltd, in association with a forthcoming hybrid application for a proposed commercial development on Land at Inlands Farm.

The TN has been prepared in order to assess the trip generation and trip distribution of the proposed development, with the results intended to be used to prepare a Transport Assessment (TA) and inform an assessment of the proposed development impact using both Swindon Borough Council’s SATURN strategic model and Highways England’s Paramics Model.

It should be noted that Highways England have not previously provided comments on this site.

Development Proposals

A hybrid planning application will be submitted to Swindon Borough Council (SBC) for consideration.

The detailed component of the application (Phase 1) comprises a 310,000ft² packaging facility which will employ approximately 1,200 people. This application will also include car parking and a site access. The site access will be taken from the local highway network.

The outline component of the application includes a future extension to the packaging facility of 180,000ft² (Phase 2a) and the building of a Science Park (Phase 2b) of approximately 140,000ft².

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

It should be noted that the layout and access of Phase 2a and Phase 2b is impacted by the provision of the Southern Connector Road (SCR), which is part of the New Eastern Villages (NEV) development. The SCR has the potential to alter the distribution of vehicle trips across the network by offering an alternative route and therefore, if included in any modelling, could influence the proposed development’s impact on the SRN.

Trip Generation Methodology

The TN calculates the trip generation of Phase 1 and Phase 2a using data obtained from an existing packaging facility, located on Frankland Road in Swindon. This site is currently run by Wasdell Properties Ltd.

Trip generation values for Phase 2b of the proposed development have been calculated using trip rates associated with the Bristol and Bath Science Park (BBSP) and the Thames Valley Science Park (TVSP), as per the TA’s submitted in support of their respective planning applications.

Phase 1 and Phase 2a Trip generation for these aspects of the development has been based on existing staff numbers, shift patterns and daily delivery schedules at an existing Wasdell site in Swindon. The TN then applies this to the forecast number of staff at the new development; 1,200 employees across Phases 1 and 2a. This approach is accepted by Highways England.

A travel survey of modes by which employees of the existing site travel to / from work is currently being undertaken. Once finalised, results of this survey are proposed to be used in order to update the TN with mode split, which will be applied to people trips at the existing site. These values will then be increased to match the forecast employee numbers at the new site, allowing the number of vehicles generated during Phases 1 and 2a of the development to be calculated. Highways England will review this mode split once survey work has been completed.

In the meantime, 2011 census data for a Swindon Middle Super Output Area (MSOA) deemed similar to that in which the site is located has been used as a comparison to results seen at the existing site.

The mode share calculated in the TN is 82% for private care. As noted above, this is calculated using data collected from the existing site. Car occupancy is calculated to be 1.08 persons. However, it is noted that WSP have suggested an adjusted car mode share of 90%; this provides a ‘worst case’ scenario. It is this value which has been used throughout the remainder of the TN to calculate trip generation. Highways England believe that it is this 90% mode split value which should be included within the final TA calculations.

The TN calculates that the existing facility generates 14 two-way vehicle trips in the AM peak hour and 68 two-way vehicle trips in the PM peak hour. It should be noted that all

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

of these trips are considered to be arrival trips in the AM peak hour and departure trips in the PM peak hour. Based on these values, the TN calculates that the proposed facility (Phase 1) will generate an additional 115 vehicles between 07:00 and 08:00 and an additional 28 vehicles between 08:00 and 09:00. Between 17:00 and 18:00, Phase 1 of the proposed development is calculated to generate 138 vehicle trips. It should be noted that these values have been calculated using a car mode share value of 90%.

A reference exercise using the TRICS database should be undertaken in the TA in order to check that the values calculated above are realistic.

The trip generation calculated above has been added to Manual Classified Counts (MCC’s) undertaken at the A419 Commonhead roundabout. It is unclear when these counts were undertaken and therefore how robust and representative they are. With the addition of proposed development traffic, as above, the Commonhead roundabout would have to accommodate more vehicles overall in the hour between 07:00 and 08:00 than in the traditional AM peak hour of 08:00 – 09:00. The TN therefore argues that 07:00 – 08:00 should be considered the AM peak hour.

Highways England request that traffic survey data for the Commonhead roundabout (as mentioned above) be appended to the TA. Mainline flows for the A419 carriageway should also be provided. This will allow values to be checked and verified. Once these have been provided and checked, a suitable hour to be assessed can be agreed.

The TN calculates that Phase 2a of the proposed development will generate an additional 69 vehicles between the hours of 07:00 and 08:00 and an additional 19 vehicles between the hours of 08:00 and 09:00. Between the hours of 17:00 and 18:00, Phase 1 of the proposed development is calculated to generate 83 vehicle trips. Again, these values have been calculated using a car mode share value of 90%.

For reference, the trip generation values included within the TN are set out below. As mentioned previously, these should be checked against rates obtained from the TRICS database.

Phase 1

Time Period One Way Trips 07:00 – 08:00 115 08:00 – 09:00 28 16:00 – 17:00 5 17:00 – 18:00 138

Phase 2a

Time Period One Way Trips 07:00 – 08:00 69 08:00 – 09:00 19 16:00 – 17:00 5

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

17:00 – 18:00 83

It is noted that the above trips for Phase 2a of the proposed development are considered ‘worst case’ scenario. This is due to no allowances being made for any new sustainable transport infrastructure which would be provided as part of the New Eastern Villages development. Although Highways England acknowledge that the above values go some way to providing a robust assessment, vehicle trip generation is not accepted until the aforementioned TRICS comparison has been undertaken and approved by ourselves.

Phase 2b Trip generation for this aspect of the development has been based on the average trip rates associated with the Bristol and Bath Science Park (BBSP) and the Thames Valley Science Park (TVSP), as per the TA’s submitted in support of their respective planning applications. These have been appended to the TN.

It should be noted that trip rates for the BBSP is based on a range of information sources including trip rates from Cambridge Science Park and Norfolk Research Park, as well as surveys undertaken at an existing BBSP building.

Highways England have checked the aforementioned TA’s which are appended to the TN and have found that two scenarios are included within the BBSP document. Highways England suggest that BBSP scenario 2 be used when calculating the average trip rates as this represents the higher of the trip rates calculated in the respective scenarios, and therefore provides the most robust assessment. This has not currently been undertaken in the TN. Trip rates should be recalculated.

Again, it is noted that the 07:00 – 08:00 peak has a similar traffic profile to the regular 08:00 – 09:00 peak and so has also been assessed. As no trip rates for this time period were assessed in the BBSP TA, a number of assumptions have been made in order to calculate trip rate values; the percentage difference between the 07:00 – 08:00 and 08:00 – 09:00 time periods in the TVSP TA have been applied to the BBSP vales. This approach is accepted by Highways England.

Comments made by Highways England above should be taken in to account when calculating vehicular trip generation for Phase 2b of the proposed development. Although Highways England agree with the methodology undertaken in the TN, values included in the TN require updating and are therefore not yet accepted.

Trip Distribution Methodology

Trip distribution for the proposed development has been calculated for each phase individually; Phase 1 and Phase 2a distribution has been calculated based on the existing facility (as per trip generation) while Phase 2b has been calculated using census data.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

It should be noted that the distribution for some aspects of the site has been altered to take in to account job type as well as the introduction of the NEV development (and SCR associated with this). These alterations have been reviewed by Highways England with our comments being set out below.

Phase 1 and Phase 2a Post code data from 69% of staff working at the existing Swindon facility have been mapped to determine the routes employees are most likely to use in order to access the proposed development. It is proposed that this information will be input into the SBC Saturn model to distribute Phase 1 development traffic onto the network.

It should be noted that all route choices will impact the SRN, namely via the Commonhead junction. However, only the M4 Junction 15 (west) and A346 Marlborough Road routes will impact on M4 junction 15, a total of 13.5%.

For reference, the distribution of employees working at the current facility and the route they would take to the proposed development is set out below. To note, this does not take in to account the construction of the NEV development (and the SCR associated with this):

Route Choice Percentage Route 1 – A419 North 12.5% Route 2 – A4259 Marlborough Road 74% Route 3 – M4 Junction 15 (west) 12.5% Route 4 – A346 Marlborough Road 1%

The above distribution is accepted by Highways England. However, due to our comments regarding trip generation, trip numbers for each route cannot be calculated at present.

Phase 2b Distribution for Phase 2b of the proposed development has been calculated using 2011 Census data for MSOAs which are representative of the Dorcan Industrial Estate. This is a large employment area, located within Swindon, which is considered by WSP to reflect similar employee travel behaviour to that expected at the proposed Science Park. This is accepted by Highways England.

Due to the uncommon nature of the Phase 2b development, the number of trips with an origin / destination of Swindon has been artificially reduced to 30%. This value is based on data collected from existing Science Parks which shows that census data is not reflective of employment sites with this purpose; when compared to an ‘ordinary’ employment site, more trips will travel from further afield, rather than settlements located near to the site. This reduction means that more traffic will use the SRN in order to access the proposed development, therefore providing a more robust assessment. This approach is accepted by Highways England.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

Highways England, along with Swindon Borough Council, also believe that there is the possibility to reduce the distribution from ‘Swindon Outskirts’, which currently stands at 25.2% in the TN. This again is due to the nature of trips associated with a Science Park type development which are more likely to be from locations further away from the site. A reduction in Swindon Outskirts trips will again increase the number of vehicles using M4 junction 15, providing a more robust assessment.

2.7% of trips are calculated to have an origin / destination within the NEV development. This is accepted by Highways England.

Modelling Scenarios

Agreed trip generation and trip distribution is to be used within SBC and Highways England’s respective models. It should be noted that trip generation and trip distribution for Phase 2b of the proposed development have not yet been agreed.

The following scenarios to be undertaken in the TA have been set out in the TN:

2018 Baseline All modelling of the 2018 Baseline scenario should be undertaken using a validated transport model. Before any modelling is undertaken, inputs, trip distribution and scenarios to be tested should be agreed with Highways England.

If it is deemed necessary to undertake any junction specific modelling, these models should be validated against both traffic counts and queue length surveys. Input data for these models should be agreed with Highways England, prior to any modelling being undertaken.

Phase 1 Opening Year • Interim Opening Phase 1 (assumed 2021) Baseline (No NEV or SCR) AM and PM peak hours; and • Interim Opening Phase 1 (assumed 2021) Baseline (No NEV or SCR) + Phase 1 development AM and PM peak hours; and

As mentioned previously, the peak hour which should be modelled will be determined once further data has been provided to Highways England.

A scenario which includes an assessment of the Baseline and any Committed Development in the surrounding area (if not already included in the model) should also be undertaken. Highways England believe SBC are best placed to comment on the committed development to be included within this scenario however we do request that the NEV development be included.

Different distributions should be used, depending on whether the NEV is or is not included within the scenario; if it is not included, the 2.7% attributed to the NEV should be distributed elsewhere.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

Phase 2a and Phase 2b • 2026 Baseline (No NEV or SCR) AM and PM peaks; • 2026 Baseline (with NEV or SCR) AM and PM peaks; • 2026 Baseline (No NEV or SCR) + Phase 1 and Phase 2 AM and PM peaks; and • 2026 Baseline (with NEV or SCR) + Phase 1 and Phase 2 AM and PM peaks.

As with Phase 1, different distributions should be used, depending on whether the NEV is or is not included within the scenario.

Highways England notes that SBC have stated that assessment of Phase 2a and Phase 2b will need to use a 2036 future year (unless a 2026 model is to be developed by the applicant).

Any modelling undertaken in order to assess the impact of the proposed development should be compliant with policy, set out in Circular 02/2013. This states that modelling should include a Base, Opening and Future year, with the Future Year being 10 years post opening or the end of the Local Plan period, whichever is longer. Highways England are happy to engage with the developer regarding modelling scenarios to be undertaken.

Conclusions

Highways England have reviewed a Technical Note, prepared in relation to the proposed commercial development on Land and Inlands Farm, Wanborough, Swindon.

The proposed development is split in to three phases and will comprise: • Phase 1 - 310,000ft² packaging facility; • Phase 2a – Future extension to the packaging facility of 180,000ft²; and • Phase 2b - Science Park (Phase 2b) of approximately 140,000ft².

Trip generation for Phases 1 and 2a have been based on an existing Wasdell site, located in Swindon. These have been increased to account for the larger quantum of the proposed development. Vehicle trip generation for the proposed development is accepted by Highways England. ‘Average’ trip rates used to calculate the number of vehicle trips generated by Phase 2b should be updated to include Scenario 2 of the BBSP TA.

As with trip generation, trip distribution for Phase 1 and Phase 2a have been based on the existing Wasdell site. This distribution calculates that 100% of trips will impact on the SRN, namely the Commonhead junction, with 13.5% impacting on M4 junction 15. This is accepted by Highways England.

Distribution of trips associated with Phase 2b of the proposed development has not been agreed. Although the reduction in trips from Swindon provides a robust assessment, it is still the view of Highways England that a reduction in trips to / from Swindon Outskirts could also be made.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

Models scenarios to be included in the TA have been set out in the TN. Any modelling undertaken should be in line with policy, as set out in Circular 02/2013. Base year models should be validated against traffic counts and queue length surveys. This modelling should be agreed with Highways England prior to it being undertaken.

Yours sincerely

Gemma Mckeown

Gemma Mckeown Planning Manager Operations Division SW - Planning & Development Team Email: [email protected]

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

Brunel House (Area 2) 930 Hempton Court Aztec West BS32 4SR

Direct Line: 0300 4700789

13 September 2018

For the Attention of Edward Snook

Dear Edward,

HIGHWAYS ENGLAND AND ENVIRONMENTAL IMPACT ASSESSMENT SCREENING OPINION: SWINDON SCIENCE PARK, INLANDS FARM, WANBOROUGH (M4J15) – REF: S/EIA/18/1472

In your letter dated 3rd September 2018, you have invited Highways England to provide comments on the scope of an EIA Report in respect of the development of a Science Park comprising up to 32,381 sqm B1b Research and Development use and 49,907 sqm B1c Light Industrial use on land at Inlands Farm, Wanborough.

Comments relating to the local road network should be sought from the appropriate Local Highway Authority.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

General aspects to be addressed in all cases:

. An assessment of transport related impacts of the proposal should be carried out and reported as described in the current Department for Communities and Local Government (DCLG) guidance on ‘Travel Plans, Transport Assessments and Statements in decision-taking’. Reference should be made to Highways England policy requirements set out in Circular 02/2013. . Environmental impacts arising from any disruption during construction, traffic volume, composition or routing change and transport infrastructure modification should be fully assessed and reported, along with the environmental impact of the road network upon the development itself. . Adverse changes to noise and air quality should be particularly considered, including in relation to compliance with the European air quality Limit Values and/or Local Authority designated Air Quality Management Areas (AQMAs) and World Health Organisation (WHO) criteria. . No new connections are permitted to Highways England’s drainage network. In the case of an existing ‘permitted’ connection, this can only be retained if there is no land use change. . Information relating to the flooding zone that the site is located is required and we stress that development must not lead to any surface water flooding on the SRN carriageway. . Works in the vicinity of the SRN should be scheduled to avoid coinciding with other construction projects in order to limit the level of disturbance to the network.

Location specific considerations: • Any assessment should consider the operation of the Strategic Road Network – in this case M4 J15 and the A419 carriageway; specifically any links to the network which could detrimentally affect its performance. This includes the M4 J15 / A419 and A419 / Purley Road / Pack Hill / A4259 interchanges. • Highways England should be involved in any discussions regarding use of the Swindon Borough Council traffic model in order to assess the impact of the proposed development. This is to ensure that the scope of the model and model outputs will be acceptable to Highways England, before work is undertaken. • It is understood that this site is not currently allocated within the Local Plan. If the site remains unallocated, Paragraph 22 of Circular 02/2013 would apply. This states that where proposals are not consistent with the adopted Local Plan a full assessment of their impact will be necessary, which will be based on the performance and character of the Strategic Road Network as determined by the presumption that the Plan proposals will be fully implemented. • Analysis of accident data for the latest available full five-year period regarding the SRN surrounding the site should be undertaken. Any relevant collision clusters or recurring accident causation factors should be assessed and properly mitigated where the proposed scheme is shown to make conditions worse • Suitable NMU facilities should be provided. These should be fully integrated to ensure that levels of severance are not detrimental. • The potential impact of construction vehicles on the SRN should be included within the assessment work.

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

These comments are only advisory, as the responsibility for determining the final scope of the scope and form of the EIA Report would rest with the Local Planning Authority.

Highways England’s comments imply no pre-determined view as to the acceptability of the proposed development in traffic, environmental or highway terms. Should the applicant wish to discuss the merits of the proposal in terms of the likely impact on the SRN please do not hesitate to contact me.

Yours sincerely

Gemma Mckeown

Gemma Mckeown Planning Manager Operations Division SW - Planning & Development Team Email: [email protected]

Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363

From:Edward Snook Sent:10 Oct 2018 12:47:59 +0100 To:Scanning Subject:FW: S/EIA/18/1472 - Inlands Farm - Environmental Health Officer

From: Tobi Parker Sent: 27 September 2018 07:56 To: Edward Snook Subject: S/EIA/18/1472

Morning Ed,

I have now had time to look at the above application. The scope of the propose EIA looks suitable to cover our concerns. The primary concerns are as follows:

Concerns surrounding dust and air quality will be answered in the construction environmental management plan.

The final, and perhaps biggest concern is the risk of a perceived loss of amenity for Wanborough residents because the development will inevitably impact upon the existing night-time scene between Wanborough and the A419/Swindon, as well as the potential for light intrusion at nearby sensitive receptor properties.

To summarise, I support the proposals made about the scope of the Environmental Impact Assessment and look forward to the application proper.

Tobi Parker

Environmental Health Officer

Healthy Neighbourhoods Team (Residential Services & Environmental Enforcement)

Email: [email protected]

From:Edward Snook Sent:10 Oct 2018 12:21:34 +0100 To:Scanning Subject:FW: S/EIA/18/1472 - Scoping Request Inlands Farm, The Marsh, Wanborough - Ecology

From: Des Hobson Sent: 27 September 2018 15:29 To: Catherine Blow Cc: Edward Snook Subject: S/EIA/18/1472 - Scoping Request Inlands Farm, The Marsh, Wanborough

Hi Catherine

I originally commented on the pre-app for this site S/PRE/17/1809.

Regarding this request (EIA Scoping Opinion Request, Turley, August 2018) to scope ecology out of the EIA, I am of the opinion that it should be included within the EIA. My reasons are:

1. 40ha of agricultural land will be developed. This major change of use will have ecological impacts.

2. The summary ecological information acknowledges that some protected species are present on the application site. A possible bat roost has been found in the centre of the site. Protected species are a material consideration in determining the planning application.

3. The scoping request acknowledges that the application site is 1.7km east of Coate Water Site of Special Scientific Interest and therefore falls within the Impact Risk Zone for the SSSI. The EIA will need to demonstrate that there will be no adverse impact on the SSSI. The 2018 National Planning Policy Framework says “development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted.”

4. The summary ecological information provided in the scoping request supplies insufficient information for us to be able to make our own assessment of their conclusion.

Best regards

Des

Des Hobson MCIEEM, CEnv

Consultant Ecologist

Masterplanning and Design

Swindon Borough Council

[email protected]

My two working days for Swindon BC are variable each week.

Highway Asset Infrastructure Management Wat Tyler West, 4th Floor, Beckhampton Street, Lead Local Flood Swindon, SN1 2JH Authority Memo

To: Planning Services From: Lead Local Flood Authority Date: 4 September 2018

Application number: S/EIA/18/1472

Proposal: Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development.

Location: Inlands Farm, The Marsh, Wanborough, Swindon,

A flood Risk Assessment (FRA) and/or Drainage Strategy (DS) will need to be submitted with any outline or full application in relation to this site. The FRA/DS should demonstrate the following:  That proposed flows from the site will discharge at or below greenfield runoff rates, or as close as practical for any areas that have been previously developed;  The impact upon the existing drainage systems is mitigated by discharging the flow throughout the management train rather than relying upon a single point of discharge;  SuDS Source Control measures to manage water quantity and maintain water quality have been implemented wherever possible and through the management train so the development is not reliant upon large attenuation features close to the points of discharge;  Proposed SuDS have been selected to provide a wide range of benefits including amenity, biodiversity and maintaining water quality;  During construction, adequate measures are proposed to control pollution to existing watercourses and groundwater;  Surface water can be safely managed within the proposed development, up to and including a 1 in 100 year plus climate change event;  Proposed and existing drainage features on the site will be maintained and managed after completion with confirmation from the relevant authority that they will adopt any systems that are being offered for adoption;  Confirmation that the applicant has consent for any outfalls from the proposed drainage systems into a public sewer or other drainage system not owned by the applicant;  The strategy mimics the existing drainage characteristics of the site by retaining and utilising any existing drainage features;  If any existing drainage features such as existing watercourses (including ditches) are proposed to be removed or culverted, these details are agreed with the LLFA by obtaining Land Drainage Consent or the Environment Agency for main rivers;  Groundwater monitoring is undertaken for a minimum of 6 months during the winter months.

Emma Chilton Flood Risk Engineer Lead Local Flood Authority From:Edward Snook Sent:2 Oct 2018 11:08:10 +0100 To:Scanning;Validation Subject:FW: EIA Scoping Opinion - Inlands Farm, The Marsh, Wanborough.

From: Pomeroy-Kellinger, Melanie [mailto:[email protected]] Sent: 20 September 2018 16:17 To: Edward Snook Cc: Liz Smith-Gibbons Subject: FW: EIA Scoping Opinion - Inlands Farm, The Marsh, Wanborough.

Dear Ed. Thanks for consulting me on the above scoping opinion. This is an archaeologically sensitive area, with part of a Roman settlement complex within the western edge of the site. I would except to see an EIA with a comprehensive chapter on cultural heritage submitted with any planning application to develop this site. The Chapter will be need to include the results from a programme of archaeological evaluation to include geophysical survey and trial trenching.

Kind regards, Melanie

Melanie Pomeroy-Kellinger BA MA MCIfA

County Archaeologist

Wiltshire Council

Tel 01249 705511

Mob 07900047633

Archaeology Advisor to Swindon Borough Council

Wiltshire and Swindon History Centre

Cocklebury Road

Chippenham

SN15 3QN http://www.wshc.eu/

From: Archaeology Sent: 04 September 2018 07:39 To: Pomeroy-Kellinger, Melanie Subject: FW: EIA Scoping Opinion S/EIA/18/1472 - Inlands Farm, The Marsh, Wanborough.

FYI.

Tom Sunley Historic Environment Record Data Manager

Please note that from 1st April 2018 our HER charges are increasing to £110 per hour (or part thereof) + VAT.

Visit the Wiltshire & Swindon History Centre - Your Passport to the Past: Archives, Archaeology & Building Records, Museums, Conservation, Local Studies. www.wshc.eu

Follow Wiltshire Council

From: Brian Jones [mailto:[email protected]] Sent: 03 September 2018 10:15 To: Archaeology Subject: Re: EIA Scoping Opinion S/EIA/18/1472 - Inlands Farm, The Marsh, Wanborough.

Dear County Archaeologist,

Please find attached consultation letter concerning the above mentioned EIA Scoping Opinion application.

Regards

Brian

Brian Jones ([email protected])

Technical Clerk

Business Support Unit

Swindon Borough Council

Tel: 01793 466247

Web: www.swindon.gov.uk

Note: Swindon Borough Council has an adopted and published Community Infrastructure Levy Charging Schedule. The Charging Schedule becomes effective from 6th April 2015. For information on how this may affect your development proposal please visit www.swindon.gov.uk/cil’

The views expressed in this email are personal and may not necessarily reflect those of Swindon Borough Council unless explicitly stated otherwise. This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error, please notify me immediately. If you are not the intended recipient of this email, you should not copy it for any purpose, or disclose its contents to any other person. Senders and recipients of email should be aware that, under the Data Protection Act 1998 and Freedom of Information Act 2000, the contents may have to be disclosed. The contents may be subject to recording and/or monitoring in accordance with relevant legislation This footnote also confirms that this email has been swept by Anti-Virus software for the presence of computer viruses. However, Swindon Borough Council cannot accept liability for viruses that may be in this email and we recommend that you check all emails with an appropriate virus scanner. ....

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This email originates from Wiltshire Council and any files transmitted with it may contain confidential information and may be subject to Copyright or Intellectual Property rights. It is intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the sender and delete the email from your inbox. Any disclosure, reproduction, dissemination, modification and distribution of the contents of the email is strictly prohibited. Email content may be monitored by Wiltshire Council to ensure compliance with its policies and procedures. No contract is intended by this email, and any personal opinions expressed in this message are those of the sender and should not be taken as representing views of Wiltshire Council. Please note Wiltshire Council utilises anti-virus scanning software but does not warrant that any e-mail or attachments are free from viruses or other defects and accepts no liability for any losses resulting from infected e-mail transmissions. Receipt of this e-mail does not imply consent to use or provide this e-mail address to any third party for any purpose. Wiltshire Council will not request the disclosure of personal financial information by means of e-mail any such request should be confirmed in writing by contacting Wiltshire Council. From:Edward Snook Sent:10 Oct 2018 12:09:44 +0100 To:Scanning Subject:FW: S/EIA/18/1472 - Scoping Request Inlands Farm, The Marsh, Wanborough

From: David Rudland Sent: 27 September 2018 14:13 To: Catherine Blow Subject: RE: S/EIA/18/1472 - Scoping Request Inlands Farm, The Marsh, Wanborough

Hi Catherine

I can’t find the consultation memo, but I can confirm that the scope of work proposed within the scoping document is acceptable, in view of the apparent agricultural land use history of the proposed development site.

Best regards

David

David Rudland Contaminated Land Officer

Public Protection Team Swindon Borough Council

Tel: 01793 466044 Web: www.swindon.gov.uk

56 Okebourne Park Swindon SN3 6AJ

24th September 2018

Planning Department Swindon Borough Council Wat Tyler House Beckhampton Street Swindon SN1 2JH For the attention of Mr Edward Snook

Application S/EIA/18/1472: Swindon Science Park Environmental Impact Assessment: Scoping Opinion Request

I object to the proposal for the reasons set out below.

The Scoping Report fails to take proper account of the Swindon Local Plan 2026 in Particular Policy NC3 which includes:

The route for the Wilts & Berks Canal as set out on the Policies Map will be safeguarded and protected from development. and

The character and identity of Wanborough, Bishopstone and Bourton will be protected by a principle of non-coalescence between the settlements. The land between the New Eastern Villages site boundary and the existing villages shall remain part of the countryside.

It cannot escape notice that the safeguarded route for the canal is not mentioned in the Scoping Report and that the proposed development site massively encroaches on the zone of non- coalescence which is clearly shown on the Local Plan mapping.

The Foreword to the Local Plan states:

This Local Plan provides the policy framework to deliver sustainable growth to 2026 and beyond. It provides a clear strategy for how we can address the challenges we face and identifies how much, where, when, and how new development will take place in Swindon Borough.

However, at the public consultation event held on 5th September 2018 it was verbally indicated by the Developer’s Agent that there has already been considerable dialogue with the Borough Council’s Planning Department resulting in the impression that the current Local Plan can be ignored and a new Local Plan is in preparation which will incorporate this development. This information is also presented at http://www.swindonsciencepark.co.uk/the-inlands-farm-site which states “The Inlands Farm Site has been promoted for a number of years for a new Science Park through the Local Plan review that the Council are currently in the process of undertaking. Promotion of the site will continue through the Local Plan process as well as the potential for a planning application for the development to be submitted.” I find this approach to be very disturbing: The current Local Plan is there to be followed until such time (around 2026) that a successor has been prepared, consulted, debated and is in place.

It is possible that Swindon politicians and civil servants have been seduced by the name given to this proposed development. They should be reminded that we have been there before: The promise of a university (which never happened) opened the door to development near Coate Water. Any development proposal therefore needs to be examined with scepticism and consideration of possible consequences. In the context of the proposed Inlands Farm development the plausible sequence of events is that a token commercial development will take place, followed by a pause and then the application to build housing on the remainder of the site. The financial gains to be made when agricultural land acquires planning consent are substantial1.

Something similar has happened with Badbury Park where the Phase 3 area, allocated in the Local Plan for employment, is now subject to an application (S/OUT/18/1140) to build houses on the site due to claimed lack of interest by commercial customers. Given that this site is still advertised as being for sale and is larger than the indicated needs of Wasdell Properties (up to 32,381 sqm of Use Class B1b (research and development) floor space and 49,907 sqm of use class B1c (light manufacturing), a decision on that planning application should be deferred while Wasdell Properties is given opportunity to purchase the site. There is also a large empty site in Dorcan which might be suitable while there is an abundance of empty space at the Synergy business park and what about Wichelstowe, which is much nearer the current factory. Given that it was indicated at the consultation that Wasdell wants a site which can be in use by 2021 then one of the sites already designated for employment in the Local Plan will be more suitable.

Swindon is becoming like a decaying tree: Still healthy on the outside but hollow and decaying in the centre. SBC should therefore file this document away for resurrection after 2026 when a new Local Plan may be in place and draw the developer’s attention to other locations available for commercial development which are consistent with the current Local Plan and preferably makes use of one or more of the brownfield sites within Swindon.

Yours faithfully,

John Ratsey

1 https://www.citymetric.com/politics/granting-planning-permission-massively-increases-land-values- shouldnt-state-get-share-1154 Comments for Planning Application S/EIA/18/1472

Application Summary Application Number: S/EIA/18/1472 Address: Inlands Farm The Marsh Wanborough Swindon SN4 0AS Proposal: Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development. Case Officer: Mr Edward Snook

Customer Details Name: Mr Mark Foyle Address: 19 Hathersage Moor, Liden, Swindon SN3 6NW

Comment Details Commenter Type: Petition Against Development Stance: Customer objects to the Planning Application Comment Reasons: Comment:Whilst I support the need for employment opportunities in the Science and Technology sector, this is an entirely imnapporpriate site for such a development. There had originally been land allocated at Commonhead for employment use but this has since been changed to residential - had there been a need for a development in this area then surely that site should've been considered before the change of use? In addition, there is a large brownfield site in nearby Dorcan which has long been vacant since the Woolworths distribution centre was demolished. This piece of land was not earmarked as part of the council's development plan and so again should not be up for consideration. There is due to be work at Commonhead for a new trunk road to the North Eastern village development - this road alone will increase noise and traffic in the area, but the addition of this science park will amplify this further. It would seem entirely inappropriate to build here as it will degrade the character of Wanborough village, and will also impose in the North Wessex Downs AONB. As a nearby resident that knows and uses this area well, I for one would be very disappointed to see this greenfield development. Comments for Planning Application S/EIA/18/1472

Customer Details Name: Mr Richard Sewerniak Address: 9 Yonder Way, Wanborough, Swindon SN4 0BX

Comment Details Commenter Type: Objector Stance: Customer objects to the Planning Application Comment Reasons: Comment:Mr Richard Sewerniak 9 Yonder Way Wanborough Swindon SN4 0BX

24th September 2018

Planning Department Swindon Borough Council Wat Tyler House Beckhampton Street Swindon SN1 2JH

For the attention of Mr Edward Snook

Application S/EIA/18/1472: Swindon Science Park Environmental Impact Assessment: Scoping Opinion Request

Dear Mr Snook,

I object to the proposal for the establishment of a Science Park at the bottom of Pack Hill near Commonhead Roundabout in Wanborough.

This is a crazy idea which makes a mockery of the Swindon Borough Local Plan 2026. Despite the claim that Wasdell Properties have been looking for a science park site for 2 years, there is no mention of it at this particular site on the Local Plan. Should Swindon Borough Council (SBC) wish to pursue the Swindon Science Park at this location, the Local Plan will first need to be completely overhauled, redrafted and re-approved. It is completely unacceptable that when wooed by a developer SBC are corrupted into reneging on their Local Plan.

This land cornered between Pack Hill and The Marsh is a greenfield site. There are a vast number of other brownfield sites within existing parts of Swindon which need to be developed and improved first rather than decimating this pristine countryside. There are perfectly good sites at the following locations: South Marston industrial estates, the new Symmetry Park on the A420, derelict land in Dorcan, Hawksworth estate and Cheney Manor, and sites already proposed for development at West Wichelstowe.

Furthermore the proposed science park at the Wanborough greenfield site does not take into account the following:

1) The revised arrangements for the Southern Connector Road 2) The effect of existing and future traffic flow 3) The Wilts & Berks Canal alignment 4) The archaeological features 5) The need for providing utilities; sewers, water supply, power, communication cables, gas pipelines, street lighting etc. which will further destroy the countryside.

Please therefore switch the site of the Swindon Science Park to one of the many a brownfield sites where services and roads are already nearby.

Your sincerely,

Richard Sewerniak Comments for Planning Application S/EIA/18/1472

Customer Details Name: Mr Nigel Chalk Address: 5 Days Close, Stratton St Margaret, Swindon SN3 4PQ

Comment Details Commenter Type: Objector Stance: Customer objects to the Planning Application Comment Reasons: Comment:There is no mention of the route of canal that is part of the Eastern development, will they support its route.

River Cole is already a major issue for Eastern Development an additional site would make the situation much worse.

All Eastern Development infrastructure has been based around existing plans and would not take additional pressure of site of this size.

Pressure on existing pinch points of eastern road network are already overloaded and would not take this additional load.

Suggest existing brownfield estate sites be used before any more greenfield sites used.