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FAO Mr Lee Burman, Development Management, Wiltshire County Council

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FAO Mr Lee Burman, Development Management, Wiltshire County Council From: Bill Ford Sent: 28 August 2017 22:21 To: Developmentmanagement Subject: Planning Reference 17/03417/OUT FAO Mr Lee Burman, Development Management, Wiltshire County Council. From William Ford, The Grey House, Draycot Cerne, SN15 5LD 28th August 2017 Dear Mr Burman, I am writing to re confirm my OBJECTION to the planning application 17/03417/OUT following my review of the revisions to the original application by St Modwen. St Modwen have clearly taken advantage of the intervening period of over three months since the first deadline for submission of comments to develop their application to try and deflect some of the concerns expressed about the original plans. It seems to be a quirk of the planning system that by comparison with St Modwen we have been allowed only 14 days to look at a further tranche of substantial documents. However despite the revisions and further embellishments, the basic plan to deliver c. 1 million of B8 storage remains unchanged and my objections outlined in my first letter of objection dated May 5th therefore remain. I do however want to make the following further comments. 1. I am confident that you have the experience in planning applications to see past some of St Modwens tactics and the rosy picture that they try and paint. I am concerned however by the licence that they take and the gross inaccuracies and factual errors in so much of their work. For example in para 14 of the response to Spatial Planning they say 'Furthermore, it (jct 17) represents the only motorway junction within Wiltshire.......'. Really ? Furthermore their arguments in para's 30-32 are disingenuous in that they only relate to transport and not to total operational costs which might well be lower at say Showell Farm by inter alia not having to provide shuttle bus transport for workers & to maintain a drainage and foul drain system. The claim that a lorry can get from junction 17 to the development site in one minute was clearly timed at 3am in the morning - for most of the day this is patent nonsense ! These may seem like trivial examples but they persist throughout this application. 2. The buildings remain monolithic and will be a blot on the landscape. In particular I draw your attention to the Appraisal photomontages 03 and 04. This is a truly hideous view and if St Modwen is planning amelioration through building colour and further planting from this direction then why not include that in the photomontage ? The Appraisal photograph 18 from Bremhill Wick entirely misses the point as of course the proposed building would not be visible on a small photo from there. It would however be clearly visible by eye from the Bremhill Ridge and from the chalk downland. I would draw your attention to para 4.3.3 of the Landscape and Visual Impact Appraisal where a key characteristic of the area is 'Wide views across whole area from higher areas of surrounding chalk downs' which will be blighted by this development & I furthermore note that the National Trust have not been consulted. 3. I have seen no comment from St Modwen to the letter from the Environment Agency dated 28th April, regarding the site falling within a groundwater Source Protection Zone 2 which therefore requires careful protection from contamination. 4. I am still concerned by the potential for nuisance of lorries waiting for their timed slots for arrival. There is no evidence of provision for this in the application and the pull off at the B4069 and B4122 junction, the lay-bys near the Great House in Kington Langley and on the A350 will be further abused as will any workable and free of cost space in Chippenham as you can see nightly on Bumpers Farm. This generates litter and waste of all kinds. 5. I have seen nothing that addresses the issue of safety on the B4122 which I remind you has seen one fatality and 23 other accidents in 2007-2014. The B4122 is also an M4 relief road should there be a motorway closure between junctions 17 and 16. This occurs several times a year - most recently only last night for seven hours. 6. I note the amended Flood Risk Assessment and the details of the volumes, flow routes & capacities of the ponds. There remain flaws in the arguments presented. Specifically the sixteen pit tests completed by Ian Farmer Associates were carried out in June 2016. These tests are the basis for establishing the natural soakaway capability of the soil and therefore for establishing the green field run off rate. Essentially the tests involve digging holes and filling them with water and timing & measuring what happens. I believe that if the tests were done during the winter with saturated soil and a higher water table the results would be quite different. Table 7.2 of the Flood Risk and Drainage Strategy is another questionable table where the answer magically comes out at 54.3 litres/second which co-incidentally is the allowed green field run off rate. This raises questions around what happens if the ponds are not maintained as there is evidently little surplus capacity. There is no mention of maintenance plans or schedules for this. Although the water holding capacity on the site has been increased and the rules state that working to 1 in 100 years plus 20% for climate change is the rainfall standard required, I would not want to have to explain this to the people downstream in Sutton Benger in the event of a Coverack (100mm of rain in 2-3 hours) or Boscastle (60mm in 2 hours) type event. There is little or no surplus capacity in the proposed system and it would be overwhelmed (& Sutton Benger flooded) by a Coverack type event. Concreting over an upland water catchment area makes no sense and is a huge risk for the council to approve. In summary I believe that this application fails under Core Policy, the Landscape is not preserved, & the issues on the B4122 have not been addressed. The economic benefits & need are overstated and the potential flood risk remains. The application remains speculative & is opportunistic and is premature pending evaluation of the effects of other developments specifically at Hullavington. I urge the Council to show leadership and a better vision for Wiltshire by rejecting this application. Yours sincerely William Ford.
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