Appendix Aii – Representations Received on Chapter 5

Appendix Aii – Representations received on chapter 5

(community area strategies) (TPL14 – TPL59) with officer comments

June 2014

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 423 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 840669 Person ID: 840663 sound? Positively prepared

Justified Identified proposed Reasons for TPL14 change unsound Effective

Consistent with national policy This amendment to the plan, referencing again indicative requirements, is not positive

and is ineffective. It introduces uncertainty about the scale of development to be planned in each of the Community Areas, and, to that extent, fails to meet the guidance in the NPPG (ID 12-002-20140306). Instead of providing flexibility it provides uncertainty and therefore fails to ensure the delivery of sufficient housing supply to meet the objective assessment of need. It is inconsistent with national policy.

The justification given is that:

Please give details of "The indicative figures also allow a flexible approach which will allow the Council including through the preparation of the Site why you support or Allocations DPD and local communities preparing neighbourhood plans to respond positively to opportunities without being inhibited by do not support the an overly prescriptive, rigid approach which might otherwise prevent sustainable development proposals that can contribute to consultation material. maintaining a deliverable five year housing land supply and delivering the strategic objectives of the plan." (para 4.28)

However, the ability to achieve a positive approach and the potential to prevent sustainable development is un-evidenced.

Conversely, using minimum targets provides a positive approach, where communities have a clear steer on what they must provide and the ability to introduce additional sustainable sites above the minimum requirement. The fact that part of a HMA is delivering more quickly should not be justification to delay of slow down the delivery required at any of the Community Areas.

The requirements for the Community Areas have been set against the settlement hierarchy and to meet the needs of those individual areas, to support sustainable development. It is important that the requirements are delivered if the overall strategy is to be delivered. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response See response to comments made on TPL11 under representation 422.

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 498 Waddeton Park Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 836038 Person ID: 840663 sound? Positively prepared

Justified Identified proposed Reasons for TPL14 change unsound Effective

Consistent with national policy Representation TPL11 & TPL14

This amendment to the plan, referencing again indicative requirements, is not positive and is ineffective. It introduces uncertainty about the scale of development to be planned in each of the Community Areas, and, to that extent, fails to meet the guidance in the NPPG (ID 12-002-20140306). Instead of providing flexibility it provides uncertainty and therefore fails to ensure the delivery of sufficient housing supply to meet the objective assessment of need. It is inconsistent with national policy.

The justification given is that:

However, the ability to achieve a positive approach and the potential to prevent sustainable development is un-evidenced.

Attached files (Please see Objective) Officer Response See response to comments made on TPL11 under representation number 495.

Consultee Agent Is the Change Mr Tim Baker Mr John Baker legally Yes Comment 541 Strategic Land Partnerships Peter Brett Associates LLP compliant? ID: Is the Change No Person ID: 841158 Person ID: 841162 sound? Positively prepared

Justified Identified proposed Reasons for TPL/14 change unsound Effective

Consistent with national policy (5.12) This says that para 4.28 clarifies ‘where additional growth above these requirements will be appropriate in accordance with the Please give details of Plan.’ However, this is not what the paragraph 4.28 does and it certainly should not do. It must be for the Housing Allocations DPD to why you support or identify where there is scope for additional sites to be accommodated. Again there is confusion between the terms ‘indicative’ and do not support the ‘minimum’ and this should be sorted out to make the intention clear and precise. consultation material. . Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Paragraph 4.28 is consistent with paragraph 5.12 and clarifies that the indicative figures allow for a flexible approach through the Officer Response preparation of the Housing Site Allocations Development Plan Document. No further change is necessary.

Consultee Agent Is the Change Mr John Baker legally Yes Comment 611 Waddeton Park Limited Peter Brett Asscoiates compliant? ID: Is the Change No Person ID: 836038 Person ID: 556318 sound? Positively prepared

Justified Identified proposed Reasons for TPL/14 change unsound Effective

Consistent with national policy Please give details of (5.12) This says that para 4.28 clarifies ‘where additional growth above these requirements will be appropriate in accordance with the why you support or Plan.’ However, this is not what the paragraph 4.28 does and it certainly should not do. It must be for the Housing Allocations DPD to do not support the identify where there is scope for additional sites to be accommodated. Again there is confusion between the terms ‘indicative’ and consultation material. ‘minimum’ and this should be sorted out to make the intention clear and precise. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Consultee Agent Is the Change Mr Mark Simpson legally No Comment 662 Primegate Properties (Hooksouth) Ltd DPDS Consulting Group compliant? ID: Is the Change No Person ID: 836270 Person ID: 556688 sound? Positively prepared

Justified Identified proposed Reasons for TPL14 change unsound Effective

Consistent with national policy These comments are made in the context of representations submitted by Primegate Properties (Hooksouth) Limited on the emerging Wiltshire Core Strategy, with respect to the promotion of Land North of M4 at Hook Street (SHLAA Site 2042), west of Swindon, for potential mixed use development including employment and housing land.

At this stage we believe that it would be premature to limit the scope of any future proposed Wiltshire Site Allocations DPD and Settlement Boundary review to the geographical locations specified; the plan period specified; and to the consideration of housing land in isolation of employment land provision. We believe that a wider scope of such studies would be necessary to appraise and identify the most sustainable development option available to accommodate the development needs and aspirations of both Wiltshire and adjacent authorities, including Swindon Borough.

Our comments are made in the context of aligning the requirements of the emerging Wiltshire Core Strategy 2026 and the emerging Swindon Local Plan 2026 (SLP2026), which has been subject to examination during May 2014, closing on 22 May. Please give details of why you support or Main Modifications of the SLP2026 that will be required prior to its adoption are understood to be identified shortly, and will include a do not support the requirement for an immediate review of that document by 2016 to extend the plan period to at least 2031. consultation material. Evidence presented by Swindon Borough of its ability to accommodate housing and employment growth requirements over the extended plan period between 2026 and 2031 included site appraisals from the Wiltshire SHLAA 2011, which identified a number of potential development sites west of Swindon, including Land North of M4 at Hook Street.

We therefore believe that within the acknowledged Duty to Cooperate working set out in Paragraph 1.15 of the draft Wiltshire Core Strategy is now ‘out of date', as there is now certainty that land west of Swindon will feature in the options for growth that will need to be considered by the immediate SLP2026 review and also a strong potential that land west of Swindon will be identified to accommodate some or all of that development need.

The potential delivery of strategic development west of Swindon commencing by 2026 would necessitate coordinated infrastructure delivery during the plan period of the current Wiltshire Core Strategy, and the coordination of this development is therefore key to achieving Sustainable Development.

The identification of a strategy for coordinating cross-border development should be identified with greater certainty and clarity to avoid delay in cross-border working and to satisfy the requirements of both the NPPF and National Planning Practice Guidance - Local Plan, specifically references to the need to identify ‘how', ‘what' and ‘when' development will be delivered. Necessary changes to the Core Strategy may be by appropriate further modifications referenced in this representation or by consequential changes or additional Core Strategy text, ideally including Paragraph 1.15.

In the interests of best aligning the emerging growth strategies of Wiltshire and Swindon in accordance with the latest updates to these strategies, we believe that a more positive policy reference should be made in the Wiltshire Core Strategy to the preparation of a review of the Core Strategy and/or a Site Allocations DPD as a plan-led approach to accommodating growth west of Swindon, whether that be housing growth to predominantly serve the needs of Swindon or employment land growth to serve the populations of both Wiltshire and Swindon. We consider these amendments desirable to fulfil the ‘Duty to Cooperate'.

In addition we reiterate our comments that the Wiltshire Core Strategy should reflect a planled approach to development west of Swindon by recognising and providing for existing and proposed employment and housing development. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response See response to comments made on TPL12 under representation number 660.

Consultee Agent Is the Change Mr Richard Burden legally Comment Cranborne Chase & West Wiltshire Downs compliant? 22 ID: AONB Is the Change Person ID: sound? Person ID: 556113 Identified proposed Reasons for TPL15 change unsound Please give details of why you support or Similar comment to TPL11 above. ‘indicative’ in place of ‘at least’ This AONB regards the modification as providing clarity with do not support the flexibility; and that flexibility inherent in ‘indicative’ can mean less as well as more development. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Officer Response Noted.

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 451 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 840669 Person ID: 840663 sound? Positively prepared

Justified Identified proposed Reasons for TPL15 change unsound Effective

Consistent with national policy Representation TPL10 & TPL15

local plans must make clear what, where, when and how development will be delivered. Indicative targets are ineffective, certainly this is not a minor amendment, and do render the plan unsound.

In terms of justification, it is our position that the Core Strategy allocates insufficient strategic sites and the Council cannot demonstrate a five-year housing land supply. This is evidenced in the attached paper produced for Gladman Developments and Gleeson Developments to support these representations. It is also supported by the trajectory information included in the Topic Paper 15 Addendum, 28 February 2014 (EXAM/84), which confirms that: Please give details of why you support or 1. In South Wiltshire, there is sufficient supply of deliverable land to support a five year supply for 4 years 2014/2015 (para 9.2); do not support the 2. In North and West HMA, there is sufficient supply of deliverable land to support a five year supply for 3 years 2014/2015 (para consultation material. 9.3); 3. In East HMA, there is sufficient supply of deliverable land to support a five year supply for 2 years 2014/2015 (para 9.4);

The NPPF (para 47 / footnotes 11 & 12) requires that in addition to the five-year supply the local plan must identify a specific supply of developable sites or broad locations for growth. The NPPG (ID 3-027-20140306) confirms that, "Local Plans can pass the test of soundness where local planning authorities have not been able to identify sites or broad locations for growth in years 11-15." This does not apply to years 6 - 10.

Whilst there is some reliance on the speedy adoption of a Site Allocations DPD and Chippenham Site Allocations DPD, the extent of the housing land undersupply is significant and acute. This level of development is strategically important for the delivery of the plan in Wiltshire and it is Core Strategy.

Clearly, a significant amount of work has already been undertaken in relation to the Chippenham sites, but no work has been undertaken in respect of potential housing sites elsewhere in the district, other than early work on the additional potential strategic sites (Strategic Sites Background Paper Exam ref. STU104) and work on the SHLAA. Any sites are likely to be controversial, particularly where such sites are being identified in a Community Area where a Neighbourhood Plan is already being progressed (and has been submitted), providing complimentary ‘additional' sustainable sites to fully meet the requirements within the Community Areas and wider HMAs.

In this context, the plan preparation period will inevitably lengthen beyond twelve months. The June 2015 programme for adoption of the Site Allocations DPD is overly optimistic. This potential delay appears to be acknowledged by new paragraph 4.26f, which makes reference to the Housing Sites Allocations DPD as follows:

"Indicative housing land supply, based around trajectories for each of the HMAs provide some detail on where the Housing Site Allocations DPD should focus and by when it needs to have sites identified in order to sustain proposed rates and scales of housing needs to have sites identified in order to sustain proposed rates and scales of housing development. This will make up the shortfall in delivery identified towards the end of the plan period." (my emphasis)

For the Core Strategy to be effective and therefore sound:

1. the ‘indicative' targets need to be ‘minimum' requirements; and 2. a number of additional strategic deliverable sites should be allocated, to enable the Council to demonstrate a five year housing land supply; 3. the Site Allocations DPD could then identify developable sites to address the 6 - 10 year period.

Notwithstanding the above, the relationship between the DPD and Neighbourhood Plan should be clarified. There are examples of Neighbourhood Planning proceeding where strategic requirements will not be met but additional sustainable sites exist. One such example is Malmesbury and we return to this under TPL31. The outcome, given the amendments to the Plan is that the Community Area will rely on its neighbours to accommodate additional land for housing, contrary to the distribution strategy. It should be made clear that the DPD, in accordance with the requirements of the Town & Country Planning Act and SA must contribute towards sustainable development and must follow the presumption in favour of sustainable development, which may mean that Neighbourhood Plans identify housing land in addition to the strategic requirements, accepting that the DPD may also allocate land at settlements or in Community Areas where Neighbourhood Plans are being progressed.

In respect of the Community Area requirements, we consider that flexibility could be introduced to accommodate the ‘rest of area' requirements at the associated towns and local service centres, if sustainable sites at those larger settlements were available.

We also have representations in respect of:

1. Pewsey 2. Malmesbury 3. Calne 4. Wooton Bassett 5. Chippenham

However, these are included under the relevant amendments to the Community Area Strategies. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response See response to comments made on TPL10 under representation number 448.

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 492 Waddeton Park Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 836038 Person ID: 840663 sound? Positively prepared

Justified Identified proposed Reasons for TPL15 change unsound Effective

Consistent with national policy Representation TPL10 & TPL15

Amending the requirements to ‘indicative' requirements, rather than, as previously, ‘at least' requirements, fails to provide a clear steer for the DPD and to local communities in progressing neighbourhood plans. The NPPG (ID 12-002-20140306) clarifies that local plans must make clear what, where, when and how development will be delivered. Indicative targets are ineffective, certainly this is not a minor amendment, and do render the plan unsound.

1. In South Wiltshire, there is sufficient supply of deliverable land to support a five year supply for 4 years 2014/2015 (para 9.2); Please give details of 2. In North and West HMA, there is sufficient supply of deliverable land to support a five year supply for 3 years 2014/2015 (para why you support or 9.3); do not support the 3. In East HMA, there is sufficient supply of deliverable land to support a five year supply for 2 years 2014/2015 (para 9.4); consultation material. The NPPF (para 47 / footnotes 11 & 12) requires that in addition to the five-year supply the local plan must identify a specific supply of developable sites or broad locations for growth. The NPPG (ID 3-027-20140306) confirms that, "Local Plans can pass the test of soundness where local planning authorities have not been able to identify sites or broad locations for growth in years 11-15." This does not apply to years 6 - 10.

has been submitted), providing complimentary ‘additional' sustainable sites to fully meet the requirements within the Community Areas and wider HMAs.

"Indicative housing land supply, based around trajectories for each of the HMAs provide some detail on where the Housing Site Allocations DPD should focus and by when it needs to have sites identified in order to sustain proposed rates and scales of housing development. This will make up the shortfall in delivery identified towards the end of the plan period." (my emphasis)

For the Core Strategy to be effective and therefore sound:

We also have representations in respect of:

1. Bradford on Avon

These are included under TPL18 & TPL19. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response See response to comments made on TPL10 under representation number 491.

Consultee Agent Is the Change Gladman and Gleeson Developments Ms Jacqueline Mulliner legally Comment Gladman Developments Limited and Gleeson compliant? 506 ID: Development Ltd Is the Change Person ID: 840921 sound? Person ID: 840924 Identified proposed Reasons for TPL/15 change unsound Introduction

1.1 This report is submitted to support representations made on behalf of Gleeson and Gladman in respect of major modification ref TPL10 and minor modifications TPL11 and TPL15, all of which rely on the Council having demonstrated a five-year housing land supply. It is our position that the Council has not met this requirement and, on that basis, the Core Strategy is not sound.

1.2 This report and calculations therein rely on the supply of housing set against the current requirements identified by main modification TPL5. This does not in any way diminish representations to TPL5, which relate to the objective assessment of housing need. Simply, the numerical calculations on supply (the number of dwellings reasonably considered to be deliverable within the current five-year period) remain capable of being applied to whatever requirement is being considered.

2. Background

2.1 It is incumbent on Wiltshire Council, as local planning authority, to demonstrate a five year supply of deliverable housing sites at all Please give details of points during the plan period, across each of the three Housing Market Areas (North and West / East / South), in order that relevant why you support or policies for housing land supply can be considered up to date. This requirement is set out in the NPPF (paragraphs 47 and 49) and do not support the further explained in the NPPG (paragraphs 3-030-20140306 and 12-008-20140306). NPPG (3-033-20140306) further states: consultation material. "Up-to-date housing requirements and the deliverability of sites to meet a five year supply will have been thoroughly considered and examined prior to adoption, in a way that cannot be replicated in the course of determining individual applications and appeals."

2.2 In respect of the 5-year supply, the test set out is an absolute one, without any scope to take into account margins of shortfall below five years.

2.3 This evidence is submitted to the Core Strategy Examination to demonstrate that Wiltshire Council cannot demonstrate a five-year housing land supply in all of the HMAs, and across the District as a whole.

2.4 In these circumstances, the plan cannot be confirmed as being sound and the NPPG 3-026-20140306 advises:

" What happens if the trajectory indicates that there are insufficient sites/broad locations to meet the objectively assessed need? It may be concluded that insufficient sites/broad locations have been identified against objectively assessed needs. Plan makers will need to revisit the assessment, for example changing the assumptions on the development potential on particular sites (including physical and policy constraints) including sites for possible new settlements. If, following this review there are still insufficient sites, then it will be necessary to investigate how this shortfall should best be planned for. If there is clear evidence that the needs cannot be met locally, it will be necessary to consider how needs might be met in adjoining areas in accordance with the duty to cooperate."

2.5 However, the Council has not demonstrated that the need cannot be met locally and has not approached adjacent authorities to address the shortfall under the duty to cooperate. Hence, further housing allocations must be made.

3. Requisite Tests of Deliverability

3.1 The NPPF paragraph 47 footnote 11 confirms the tests of deliverability, i.e. what must be demonstrated in order for a site to be included in the 5 year supply. The approach to the test is different for sites with planning permission and for those without:

"To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans."

3.2 This is further clarified in the NPPG, 3-020-20140306 - 3-023-20140306:

1. There must be confidence that there are no legal or unresolved land ownership issues, such as multiple ownerships; 2. The existence of planning permission does not necessarily mean the site is available; 3. There must be a reasonable prospect that the development will be developed at a particular point in time, including taking into account the capacity to sell the development; 4. The assessment must consider constraints, including environmental constraints, and actions to overcome these; 5. Lead in times, build out rates and information from developers and agents is important.

3.3 NPPG paragraph 3-031-20140306 further confirms that:

"Deliverable sites for housing could include those that are allocated for housing in the development plan and sites with planning permission (outline or full that have not been implemented) unless there is clear evidence that schemes will not be implemented within five years.

However, planning permission or allocation in a development plan is not a prerequisite for a site being deliverable in terms of the five- year supply. Local planning authorities will need to provide robust, up to date evidence to support the deliverability of sites, ensuring that their judgements on deliverability are clearly and transparently set out. If there are no significant constraints (e.g. infrastructure) to overcome such as infrastructure sites not allocated within a development plan or without planning permission can be considered capable of being delivered within a five-year timeframe. The size of sites will also be an important factor in identifying whether a housing site is deliverable within the first 5 years. Plan makers will need to consider the time it will take to commence development on site and build out rates to ensure a robust five-year housing supply."

3.4 Windfalls can be included within the supply, as follows:

"Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic delivery rates and expected future trends, and should not include residential gardens." (para 48).

4. Baseline Requirements

4.1 In accordance with main modification ref TPL5, the baseline housing requirement across the plan area is the delivery of at least 42,000 dwellings over a 20 year period, 2006 - 2026 (2,100 dpa). In order to meet requirements for the current five-year period, commencing 1 April 2014, the Council will therefore need to demonstrate the delivery of 27,300 dwellings relating to the period 1 April 2006 - 31 March 2019 (13 years x 2,100).

4.2 In accordance with TPL10, this is divided across three HMAs as follows:

1. North & West HMA 16,081 2. East HMA 3,861 3. South HMA 6,773 4. Total 26,715

4.3 This distribution, to the HMAs, excludes 900 dwellings to be located west of Swindon (585 dwellings relevant to the 13 year period from the commencement of the plan period to the end of the current 5 year period). However, Topic Paper 15 dated January 2012 makes it clear that, in identifying the objectively assessed need for Wiltshire:

"These projections forecast the requirements for Wiltshire alone and make no allowance for the requirements of the neighbouring settlement of Swindon. In previous policy, a specific allowance for housing on the edge of Swindon but within Wiltshire was made which was developed in order to meet the needs of the population of Swindon rather than Wiltshire. The requirements developed in this paper include no such allowance, and any further development (including that at Moredon Bridge) at the West of Swindon should be seen as being in addition to that required for Wiltshire alone." (paragraph 5.6, our emphasis)

4.4 Whilst the Sustainability Appraisal, to which the 10th Procedural letter refers vis a vis the revised provision of 42,100 homes, took into account the provision of 200 homes at west Swindon, the SA also notes that ‘west Swindon does not form an HMA' (SA February 2012 footnote 23). SA paragraph 4.29 confirmed:

"Moredon Bridge at the West of Swindon for 200 homes. Development in this area does not meet the requirement for Wiltshire and so this has been excluded from the defined housing market areas. Furthermore, these 200 dwellings are an allowance rather than a requirement, and should they not be delivered on the identified site, there will be no requirement to find an alternative."

4.5 Increasing provision to 900 homes at west Swindon, whilst supported by planning consents at Moredon Bridge and now Ridgeway Farm, is therefore unjustified. These commitments should sit outside the distribution methodology, principally because they relate to Swindon's needs and therefore sit outside Wiltshire's revised requirement of 42,000.

4.6 The revised baseline requirement, adding 585 homes back in (proportionate to 13 years - 900 homes delivered over a 20 year period) would be:

1. North & West HMA 16,433 2. East HMA 3,946 3. South HMA 6,921 4. Total 27,300

4.7 In line with the NPPG 3-035-20140306, the extant baseline requirement for the next five years, after completions, will include any shortfall accumulated 2006 - 2014.

4.8 Further, a 5% or 20% buffer needs to be added to the baseline requirement, subject to an assessment of past delivery within each HMA. This is addressed below.

4.9 Before moving to the assessment for each HMA, we note the invitation in the 10 th procedural letter to rely on some delivery of sites, still to be allocated through the Site Allocations DPD and/or Neighbourhood Planning, provided the timescales to progress these development plan documents (as set out in the LDS) allow for this. However, as reference above, if this reliance is to be had then Wiltshire will need to provide robust, up to date evidence to support the deliverability of sites, ensuring that their judgements on deliverability are clearly and transparently set out.

5. The Buffer

5.1 The NPPF (47) requires a buffer to be added to the 5 yr HLS. In many cases this will be a 5% buffer but where there has been persistent under-delivery a 20% buffer must be added to the requirement (moved forward from later in the plan period). For the purposes of the representation submitted, only the North & West HMA and East HMA have been assessed.

5.2 Wiltshire's ‘Housing Land Supply Statement April 2013' (February 2014) sets out past delivery for the period 2008 - 2013 against the Wiltshire & Swindon Structure Plan 2016 (WSSP). However, this approach is unjustified, as follows.

5.3 The approach to persistent under-delivery has been considered in the High Court involving a case at Tetbury, Gloucestershire (CO/3629/2013, CO/3626/2013, CO/7880/2013 - 27 November 2013). This judgement (paragraphs 42 - 54) clarifies:

1. The decision maker would need to have regard to a reasonable period of time, accepting that the past 5 years is reasonable; 2. There has to be a record of under delivery, with some measure of requirements and then record of failure to deliver persistently; 3. It would be appropriate to be open to the decision maker to identify an appropriate measure of housing need either separately from the development plan (in that case the Structure Plan) as a means of reinforcing the basis of the development plan; 4. Allowing some fluctuations, both above and below the target, is consistent with the NPPF (the use of averages achieves this); 5. The Inspector was entitled to take into account the fact that the Structure Plan requirement was artificially low; and 6. The purpose underlying NPPF 47 is to ensure there is an adequate supply for the future.

5.4 In this context it is relevant that the Swindon and Wiltshire Structure Plan 2016 (WSSP) was adopted 1 April 2006 and covered the period 1996 - 2016. It was prepared jointly by Wiltshire County Council and Swindon Borough Council in accordance with the Town and Country Planning Act 1990 (as amended by the Planning and Compensation Act 1991). Examination of WSSP took place June - July 2004, the Panel Report was published October 2004. It was an Alteration to the Wiltshire Structure Plan 2011 (adopted 2001), altering and rolling forward the policies therein. The Foreword states, "The Plan forms part of the development plan for Wiltshire for a period of three years or until it is replaced by the new Regional Spatial Strategy for the South West." It contained an artificially low annual housing requirement for the former boroughs of North Wiltshire, West Wiltshire and Kennet (now forming the North & West Wiltshire HMA and East Wiltshire HMA). This is evidenced by the then emerging and significantly advanced regional spatial strategy (dRS), which, in 2008 (the start of the period assessed by the Council in respect of past delivery) had been through examination and was subject to changes, published by the SoS for consultation. In each of the three former boroughs, the dRS significantly increased annual housing requirements:

(Please see table in attached rep - council's interpretation)

5.5 Of relevance to the position is that, in the immediate period before the publication of the NPPF, PPS3 (first published November 2006) confirmed, under a section entitled ‘Delivering a flexible supply of land for housing', that: "In circumstances where Regional Spatial Strategies are in development, or subject to review, Local Planning Authorities should also have regard to the level of housing provision as proposed in the relevant emerging Regional Spatial Strategy." (para 53)

5.6 In considering the past position, it is also relevant that PPS3, under ‘Monitoring and review', stated: "Consider delivery performance in the context of the objectives for the housing market area and region as a whole, as set out in the Regional Spatial Strategy" (para 76 last bullet)

5.7 Therefore, whilst disaggregation to individual towns is not specifically addressed by Tetbury, it is relevant that the national policy in respect of monitoring has always been concerned with the HMA and that the ongoing reason for this is as reported in the Tetbury judgement:

"The purpose underlying para 47 is to ensure that there is adequate housing for the future."

5.8 Hence, Wiltshire should have been looking to deliver the dRS requirements across the boroughs/HMAs.

5.9 It is further relevant that: 1. in respect of North Wiltshire, the WSSP fell significantly below the adopted requirement in the North Wiltshire Local Plan, which had been adopted after the WSSP and should, in any event, take precedence in accordance with section 38(5) of the Planning and Compulsory Purchase Act; 2. in respect of West Wiltshire, the adopted West Wiltshire District Plan 1st Alteration (2004) the requirement was for the deliver of 700 dwellings per annum during the period 1991 - 2011; 3. in respect of Kennet, the district plan adopted 2004 required the provision of 350 dwellings per annum during the period 1991 - 2011; 4. the submitted draft Wiltshire Core Strategy (Feb 2012), which covers the period from 2006, also increased the provision in the HMAs from that set in the WSSP - in the case of East Wiltshire from 262 dpa to 275 dpa and in the case of North & West Wiltshire HMA from 1,037 dpa to 1,070 dpa.

5.10 It is therefore a fully justified approach to set aside the WSSP when looking at how the District has performed in terms of past housing delivery and consider the implications of the following:

(Please see table in attached rep - council's interpretation)

5.11 It is clear that across the North and West HMA (former North and West Wiltshire cumulatively) there has been serious and persistent under-delivery, focussed on North Wiltshire, whilst in the East Wiltshire HMA there has not been. Hence 20% should be applied to the former and 5% to the latter.

6. The Requirement: Conclusion

6.1 Taking the above into consideration, together with completion figures 2006 - 2013, the outstanding requirements are set out in the table below:

(Please see table in attached rep - council's interpretation)

7. Deliverable Supply Assumptions

7.1 Using the Council's own five-year delivery figures of 7,285 in North & West HMA and 1,545 in the East HMA (EXAM91 Table 2), Wiltshire cannot demonstrate a five-year housing land supply within the North & West HMA (-275 based on 5% buffer), whilst it can within the East HMA (+169). In terms of Wiltshire as a whole, for which the Council's trajectory shows a delivery of 12,874, the supply is marginal (+142 dwellings). It would only take one year's slippage in the delivery of one or two of the strategic sites to reduce the supply to less than five years.

7.2 The components of supply, on which the Council relies, are identified at EXAM91 Appendix 1. These comprise a combination of permitted sites, allocated sites (in the local plan and eWCS), windfall sites, vision sites and strategic sites identified in the emerging Wiltshire Core Strategy.

7.3 In terms of the trajectories, where development is delayed the effect on the trajectory is to roll it forward, losing later years of supply. This is because the first years reflect the time taken to establish delivery on sites. For example, if there is delay of one year in the delivery of North Chippenham then there is a loss of 120 dwellings from the trajectory.

7.4 In order to include a site in the supply it must be deliverable and any reliance on windfalls must be realistic, in accordance with the NPPF and NPPG. The starting point is that sites with planning permission should be considered available unless there is evidence that schemes will not be implemented, but issues such as multiple land ownership, infrastructure constraints, lead in times, delivery rates and market rates are all relevant considerations. Where planning permission has not been granted sites must be suitable with a reasonable/realistic prospect that they will be available and viable at the point envisaged.

Methodology

7.5 Given the approach to sites with planning permission, this evidence focuses on strategic allocations, for which planning permission has yet to be granted. In assessing reasonable prospects of delivery on these large sites the following has been considered:

1. Whether the allocation of the site relies on a later DPD, and how this might affect delivery; 2. Whether the site has been released by the landowner for development and therefore available now; 3. The likelihood of a site receiving outline planning consent and then reserved matters consent within a timescale that gives a realistic prospect of delivery within the five year period; 4. The timescales for realistic delivery once construction on a strategic site commences.

Delivery Rates

7.6 With regard to the timescales for gaining planning consent, experience of strategic sites suggests the following timetable.

(Please see table in attached rep - council's interpretation)

7.7 These sites inevitably have longer lead in times than smaller sites because of the need for up-front infrastructure and inevitably are more complex and attract more objections. Often they require environmental impact assessment and are subject to lengthy negotiation through the application process to resolve technical issues and in agreeing the s106.

7.8 For example, Terence O'Rourke Ltd has been involved in the planning promotion of the Amesbury urban extension, located in the former Salisbury District (South Wiltshire) since the mid 1990's. The following provides an indication of progress:

1. An outline planning application for 550 dwellings with an ES was submitted to Salisbury District Council in May 2002. The Council resolved to approve the application in October 2003 against the backdrop of an allocation for 550 dwellings in the emerging Local Plan. Planning permission was issued 1 March 2005 following the adoption of the local plan in 2004 and signing of a section 106 agreement with the District and County councils. Construction commenced spring 2006. Two developers were involved (Bloor Homes and Persimmon Homes) with 275 units each. The development is known as Archers Gate and is now complete. 2. Persimmon Homes submitted a detailed application to Salisbury District Council for 12 units in October 2009 and secured permission on 31 March 2010. The development is now complete. 3. An outline planning application for 170 units on land known as the ‘White land' (undeveloped but within the red line area of the original outline permission) was submitted to Salisbury District Council in October 2009. The application did not require an EIA. The permission was issued December 2010 following the signing of a section 106 agreement. Construction commenced late 2010 with 2 developers (Bloor and Persimmon). This development is now complete. 4. A further outline planning application for 460 dwellings with an ES was submitted to Wiltshire Council in March 2012. A resolution to grant was received 5 November 2012, the section 106 agreement was signed May 2013 and permission issued. Detailed applications for the access roads were submitted September 2013 and approved March 2014. Residential reserved matters for an initial 118 have been submitted but not yet approved. 5. A further outline planning application for 143 units was submitted with an environmental statement November 2013. A decision is still awaited.

7.9 Likewise, in respect of the development at Trowbridge, known as ‘Castle Mead', the site was allocated in 2004, with the adoption of the West Wiltshire Local Plan First Alteration, the outline planning application for 650 dwellings was submitted in November 2004, resolution to grant was given in July 2005 but permission was not issued until December 2010. The first reserved matters applications were granted in 2011, residential development commenced January 2012. The sales office opened in May 2012. Persimmon and its sister company Charles Church are both building on site, offering two outlets.

8. Assessment Overview: North & West Wiltshire

8.1 The various trajectory positions are summarised below and then explained further in relation to each site. The difference in the five year supply between the Council and Gleeson/Gladman is 1,748 dwellings: Council position (April 2014 Trajectory)

(Please see table in attached rep - council's interpretation)

8.2 Westinghouse Recreation Ground, Church Farm, Station Road and Buckbridge Farm are all ‘noted' by the Council as being undeliverable within the five-year period. Unlike the Council's trajectory, these should therefore be discounted from the supply

Landers Field Chippenham

8.3 Wiltshire Council owns Landers Field (Land south west of Abbeyfield School). The site is identified as a strategic allocation in the eWCS to deliver 1 ha of employment land and between 100 - 150 dwellings. All of the Chippenham strategic allocations will now be reconsidered in a Chippenham Site Allocation DPD.

8.4 The site is not optioned to or being promoted by a developer, neither is it being marketed by Wiltshire Council. Previous email correspondence from the Strategic Projects and Development Manager at Wiltshire Council, dated 6 December 2012, states that that the site will be placed on the open market "as soon as the Council's Core Strategy is adopted" (appendix 1) . The email clarifies that, "Wiltshire Council is a single corporate body and therefore it would be inappropriate for the site to be offered for sale contrary to the existing Local Plan Policy and in advance of the Core Strategy." 8.5 The removal of the site from the Core Strategy has introduced a significant delay in the allocation of the site, which will now not be until June 2015, when, it is expected, the Allocations DPD is adopted, in accordance with the LDS January 2014.

8.6 If the site is allocated, in due course, it would then need to be marketed. Following which there would be a need for contractural arrangements. This process is likely to introduce a delay of 12 months, following which planning applications need to be submitted and determined, S106 signed, pre-commencement conditions discharged and site works undertaken before first completions. It is therefore evident from the timescales described earlier that the prospect of any delivery of homes on this site before early 2019 is unrealistic. In terms of the NPPF and NPPG requirements, this site should would, at best, only contribute 50 dwellings to the five-year HLS.

North Chippenham

8.7 The North Chippenham site was identified in the submitted WCS to accommodate 750 new homes and 2.5ha of employment land. A consortium, comprising Barratt Development, Persimmon Homes and Heron Land, submitted a planning application for up to 750 dwellings (12/00560/OUT) in February 2012. This application received a resolution to grant permission on 16th April 2014, subject to a s106 agreement, including the delivery of a distributor road and off-site highway works.

8.8 Given that the applicant must still negotiate a s106, submit reserved matters and undertake significant site preparation works to gain access first occupations are highly unlikely within the 18 months. The delivery, as set out in the Council's trajectory, is therefore delayed by one year.

Rawlings Green

8.9 The Rawlings Green site, to the south east of Chippenham, is identified in the submitted WCS to accommodate 700 homes and 6ha of employment land, however this allocation has been removed from the Core Strategy and will be addressed in the Chippenham Site Allocations DPD. There remains significant uncertainty as to whether this site is one of the most sustainable and suitable options for Chippenham and ultimately whether it will be allocated in the DPD.

8.10 The site is being promoted by Barratt Homes and will be accessed via the distributor road to be built in association with the North Chippenham site, linking from the A350, Malmesbury Road, to Parsonage Way. To access the site, two third party landownerships must be crossed, including the railway line.

8.11 There is no application in respect of this site and access is reliant on a significant build programme and third party land negotiations.

8.12 Given the timing of delivery on North Chippenham, and the land ownership and access issues, even if an outline planning permission were granted in advance of the DPD, there is no reasonable/realistic prospect of this site delivering housing within the 5 year period.

8.13 This position is further supported by email correspondence dated 19 December 2013 from the agent (Chesterton Humberts) acting for an owner of a 28ha southern section of Rawlings Green site (which runs along the north side of the River Avon), which indicates that the landowner will not take the land at Rawlings Green forward until the option on his land at North Chippenham has been exercised (see appendix 2).

8.14 This site should therefore be deleted from the five-year trajectory.

South West Chippenham (Patterdown & Rowden)

8.15 South West Chippenham is identified in the submitted WCS to accommodate 800 homes and 18ha of employment land, however this allocation has been removed from the WCS and will be addressed in the Chippenham Site Allocations DPD. There remains significant uncertainty as to whether this site is one of the most sustainable and suitable options for Chippenham and ultimately whether it will be allocated in the DPD.

8.16 The site is being promoted by Crest Strategic Projects and Redcliff Homes and there is a live outline application on the employment part of the site, submitted 21 February 2013. The application was reported to the Strategic Planning Committee 30 July 2013 with a recommendation to delegate approval to officers to await submission of the agreed revised parameters plan and draw up a s106 in regard to highway matters. The application has yet to be determined.

8.17 It is now unlikely that the applications will be able to pursue a successful planning application until the DPD is further progressed. Given the current uncertainty, on the basis that there is no allocation and no application as yet, for a site of this scale and complexity, considering past evidence of delivery timescales, there is no reasonable/realistic prospect of first completions are unlikely before 2018/19. Delivery has slipped two years from the Council's trajectory.

SE Trowbridge (Ashton Park)

8.18 The site is proposed as a strategic allocation in the WCS comprising 2,600 new homes and 15 ha of employment land. The delivery requirements, as set out in the eWCS, include:

1. 40% affordable housing 2. Foul and surface water infrastructure including off site flood storage features 3. Re-enforcement of the electricity network and primary sub-station 4. Two new primary schools 5. A site for a new secondary school

8.19 There is currently no planning application for the site, which is controlled principally by Persimmon Homes, also developers at the adjacent Castle Mead site where 450 of the 650 permitted dwellings remain outstanding. In respect of the Castle Mead site, Persimmon (together with its sister company Charles Church) is delivering about 100 dwellings per annum (sales office opened May 2012, 200 completion by April 2014). It took eight years to progress from an allocation in 2004 to achieve first completions in 2012. Reserved matters are not progressing to an extent that would suggest an increased delivery rate. Our assessment, on the evidence of current delivery rates, is that the Castle Mead development in unlikely to be completed until 2018/2019. 8.20 Persimmon do not intend to sell on the site, to involve other developers, and it is therefore clear that the south east Trowbridge site will follow Castle Mead. The Regional Land Director at Persimmon has previously indicated the intention to develop the site as a medium term option (see appendix 3):

"There are a number of currently unresolved technical issues regarding infrastructure and we are currently building out our Castle Meade site, off Green Lane. We remain committed to the site and to bringing it forward, we are actively promoting the site through the local plan process. However, we do view it more as a medium term option and are not currently progressing towards a planning application."

8.21 Whilst this position was altered to support the site's allocation through the WCS examination hearing session last year, there is no evidence that Persimmon intends to submit a planning application in the near future. It is clear that the site is not progressing to the timescales outlined in the April 2013 Statement of Common Ground and that the original position described by Persimmon, in January 2013, is likely to be more accurate.

8.22 In any event, this will be a complex planning application. The eWCS indicates that the site is near to the Bath and Bradford-on- Avon SAC, and applications will need to be screened for appropriate assessment, and any such assessment would have to conclude "no likely significant effect" . Undoubtedly, EIA will be required, which will require significant survey and technical work to support it. To date, no screening opinion or scoping request has been submitted. This supports the position that an outline planning application is not being positively progressed at this time.

8.23 Evidence from previous applications, at Amesbury and Trowbridge suggests that, once submitted, determination will take some time. Then, the development will require significant infrastructure to support it, including two new primary schools and a secondary school, and significant transport infrastructure contributions, as set out in Persimmon's comments to the strategic allocation made on the 2 April 2012, in regard to the potential viability issues the transport infrastructure in particular, may raise.

8.24 Whatever the forward delivery rates might be, there is no realistic prospect of this site delivering within this five-year period.

West of Warminster

8.25 The site forms a proposed strategic site allocation in the eWCS. The draft allocation is for the delivery of 900 dwellings and 6ha of employment. Delivery requirements, set in the eWCS, include:

1. 40% affordable housing 2. Protect the setting and the views of the AONB 3. Contribution towards a phosphates management plan or alternative 4. Surface water management 5. Capacity improvements to the public sewer 6. Reinforcement of the electricity network 7. New link road to connect Bath Road, Victoria Road and Thornhill / St Andrews Road 8. Avoid a negative impact on West Street 9. Provide a new bus service 10. Financial contribution to a two form entry primary school 11. Financial contributions to secondary education 12. Financial contributions to Stone Curlew project to offset recreational impact on 13. Salisbury Plain SPA

8.26 Persimmon Homes (Wessex) and Hannick Homes control the majority of the site. No planning application has been submitted.

8.27 Undoubtedly for a scheme of this size and complexity EIA will be required in association with a planning application. This will require significant survey and technical work to support it and there will be objections. The Core Strategy confirms a Strategic Flood Risk Assessment (Level 2) is required. Persimmon's representation to the pre submission Core Strategy requests "the overall requirement at the West Warminster Strategic site to be reassessed, having regard to the viability of the urban extension and the various infrastructure items sought by the Council" . The infrastructure requirements include significant highway works. However, the current schedule of proposed changes make it clear that the development quantum is set at 900 homes and 6 hectares of employment.

8.28 The development template for West of Warminster states:

"The area identified as ‘Indicative Mixed Use' represents an area of land that is much larger than that required to deliver 900 homes, 6 ha employment and associated facilities. The final development area is yet to be identified through a comprehensive master planning process with the local community. The master planning process will need to consider all aspects of this development template and the larger area of land provides space for further mitigation if required to cover areas such as landscape and the impact on the Warminster Conservation Area. It does not provide for additional development and the development quanta will remain set at 900 homes and 6 ha employment."

8.29 With the final development area not yet agreed and significant technical work still to be undertaken, there is no reasonable prospect of completions before 2018/2019.

Hunters Moon

8.30 This is a identified as a large permitted site for 454 dwellings. The Council resolved to grant outline planning permission for 450 homes and full permission for the first phase of 103 homes on 22 January 2014. The s106 has not yet been signed and on the basis that, typically, it will take a year to discharge pre-commencement conditions, prepare the site and deliver first completions, the trajectory should commence from 2015/16.

Conclusion on North & West Wiltshire HMA HLS

8.31 The above reduces the HLS within the North & West HMA by 1,748 dwellings (2,697 - 949) from the Council's position. The Council's overall position on HLS, in the April 2014 HLS Position Statement (EXAM91), is a total deliverable supply of 7,285 dwellings 2014 - 2019. Removing 1,748 dwellings from this supply equates to a remaining supply of land for 5,537 dwellings.

8.32 With reference to the requirements (7,560 including a 5% buffer or 8,640 using a 20% buffer), the Council does not have a five- year housing land supply and additional allocations will be required.

8.33 It is accepted that the Site Allocations DPD may be able to satisfy some of this requirement. However the scale of the shortfall is significant, ranging between 2,023 -

3,103, and the timescale for the adoption of the DPD (June 2015) is overly optimistic, given that consultation on scoping has just ended. Significant completions from any additional sites allocated in the DPD before the end of the current five year period is unrealistic. Even assuming all newly allocated sites could deliver 100 homes within the five year period, 31 sites would need to be allocated in North and West Wiltshire.

8.34 To give greater certainty a number of additional strategic sites should be allocated at this stage, in the Core Strategy.

9. Assessment Overview: East Wiltshire

9.1 The situation in East Wiltshire is less acute, however, the Council's trajectory, which shows the delivery of 1,394 dwellings within the five-year period (excluding windfall allowance) does rely on completions from sites at two sites that we consider to be unrealistic.

9.2 The Garden Centre site at Granby Gardens, did have an outline planning application submitted and an appeal running. The appeal was withdrawn earlier this year because of unresolved land ownership and highway issues. A new application has yet to be submitted. Given experience of delivery timescales, it is unlikely now that first completions will occur in 2015/16. Hence the Council's trajectory has slipped one year removing 80 dwellings from the supply.

9.3 In respect of the Salisbury Road allocation, for 220 dwellings, there is no planning application submitted in respect of the site. In the 2010/2011 Annual Monitoring Report, delivery in respect of this site was anticipated in 2014/2015, on the basis of a report by the developer. This has clearly slipped and, in the circumstances, there is no realistic prospect of delivery before 2018/2019, removing 120 dwellings from the trajectory.

9.4 The effect of delays in respect of these two sites is to remove a total of 200 dwellings from the trajectory. Given the five-year requirement of 1,376 dwellings, the Council cannot demonstrate a five year housing land supply, even if windfalls are included.

10. Conclusion

10.1 There is a clear five year housing land supply shortfall in both the North & West Wiltshire HMA and East Wiltshire HMA. The effect of this across the district as a whole is also to provide a shortfall.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

840921 TOR Gladman Gleeson main report.pdf Attached files (Please see Objective) 840921 Gladman Gleeson Appedicies.pdf Officer Response See response to comments made on TPL10 under representation number 416.

Consultee Agent Is the Change Mr C Simpkins legally Comment 512 RPS Swindon compliant? ID: Is the Change

Person ID: 391610 Person ID: sound? Identified proposed Reasons for TPL/15 change unsound Proposed Modification TPL I 5 - Core Policy 2 The representations in relation to this proposed modification relate to the following specific matters.

I ) The determination of OAN The plan itself does not appear to mention OAN. The addendum to Topic Paper IS refers to it at para 2.1 I in the context of the inspector's IOth procedural letter. There is, however, no definitive statement as to what the LPA regards as OAN in the context of paragraph 47 of the NPPF.

The implication of the Council's response to the inspector's 10th procedural letter is that the figure of 44,000 dwellings is accepted as OAN for the purposes of the proposed modification. However at the Coate Bridge inquiry, the Council's evidence was that the "starting point" in this regard was a figure derived from the 20 I I based household projections of 39,400 dwellings. The basis for this conclusion is derived from Section I 0 of the NPPG that the council regard as a change in government advice.

Since the CB inquiry concluded, we have attempted to establish whether or not the council is in fact disputing the Inspector's assessment of OAN i.e. 44,000 dwellings, but no definitive response has been forthcoming. Please give details of why you support or If the Council do consider that the inspector's assessment is not robust, and that OAN is in fact less than the figure of 44,000 then this do not support the would clearly have fundamental implications for the proposed modifications. It would at the very least require a re-consideration of the consultation material. matter based on the LPA's position and its interpretation of the NPPG on this issue. This would require a further period of consultation to enable the council's case to be considered and responded to in detail.

Since this representation was drafted, the council have sent a letter to the eWCS Inspector dated 19th May 2014 suggesting that the NPPG does indeed change the position in relation to OAN. It is unclear precisely what figure they now rely on but the obvious implication is it is considered to be less than 44,000. We also understand that Wiltshire Council's representations to the Swindon Local Plan Examination include the suggestion that it is meeting full OAN in the eWCS. These factors emphasise the importance of clarity as to the LPA's position on this fundamental issue and the need for an opportunity for comment.

2) Split between HMAs

The following table summarises the proportional split between HMAs as between the

previous proposals and the proposed modifications. HMA Previous % Proposed%

East Wiltshire 14.9 14.1

N and W Wiltshire 57.8 58.9

South Wiltshire 26.8 24.8

Swindon West 0.5 2.1

The only HMA in which the proportion has increased is thus North and West Wiltshire. The biggest proportional increase is in relation to West Swindon where the figure of 900 dwellings is disregarded entirely, effectively reducing the Wiltshire requirement by that amount. Whilst in the previous proposals the West Swindon figure was represented as an additional allowance, it is therefore now being used as a means of reducing the requirements. This is completely unjustified. The overall proposed requirement represents a potential proportion of OAN as assessed by the eWCS Inspector that arises in Wiltshire. It must therefore be met in Wiltshire.

In relation to the site at Coate Bridge, Devizes, an increase of 350 dwellings for the EWHMA would take the proportional contribution for that particular HMA back to its previous level. Whilst that is, in itself, not a justification for such an increase it does support the proposition that recognition of the contribution that this unconstrained site would make to boosting housing supply would not result in a disproportionate increase in housing requirements.

3)The "gap" between OAN and proposed housing requirements on the assumption that a robust assessment of OAN is 44,000 the addendum to Topic Paper 15 does not begin to justify an overall, lower requirement based on the guidance in paragraph 47 of the NPPF. Inevitably this conclusion relies on a general judgement as to the efficacy of the exercise that has been undertaken. It is by any standards, however, a cursory assessment of constraints to development. It does not, in our view, begin to support the view that Wiltshire is so constrained that it cannot accommodate an additional 2000 - 3000 dwellings in the period to 2026.

The supplementary Sustainability Appraisal (EXAM 99) that appeared on the council's website at some point after the consultation period began also does not look specifically at an OAN figure of 44,000 dwellings. This, again, must mean that the council does not accept the Inspector's assessment but there is, again, no indication in this document as to what OAN is considered to be and why.

In relation to the specific issue of the EWHMA and the Coate Bridge proposal however, as indicated above the council's position is that this site is not constrained by any specific polices in the NPPF and is thus capable of partially filling any "gap" between OAN and requirements. On this basis there thus can be no issue in recognising this in the final plan providing OAN is higher than the proposed requirement.

If, however, the council is proceeding on the basis that there is in fact no "gap" between OAN and its proposed housing requirements i.e. they are effectively one and the same then the situation is fundamentally different, hence the importance of the LPA establishing and justifying its position on this key issue. This must be done in the context of the proposed modifications rather than through less than definitive correspondence and submissions to plans in a neighbouring authority.

4)Deemed unsustainability - TPL 15 includes the proposition that proposals outside development limits will be "deemed unsustainable". This would lead to situations where the presumption in favour of sustainable development in the NPPF is negated in circumstances where settlement limits are out of date. Proposals cannot be rendered unsustainable on the basis of a policy statement. This

reference should thus be removed. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The Council set out what it considered to be the objectively assessed need (of 37,000 homes) in Topic Paper 15 and throughout the hearings. In the 10th procedural letter, the Inspector states that his interpretation of all the evidence leads him to find that the objectively assessed housing need across Wiltshire is in the region of 44,000 homes for the plan period.

The Inspector has since asked the Council to provide comments on the effects of the PPG. The PPG clearly identifies that the starting point for the objectively assessed need is that identified by the 2011 based interim household projections, which indicate a figure of 39,400 homes (see para 4.2 of EXAM19). The Council has responded in this context (see letter of 19 May 2014). Although the PPG suggests that OAN could be lower for Wiltshire, taking a cautious approach and in recognition of the Government’s aim to increase housing supply, the housing requirement should remain at 42,000.

The Inspector notes the broad acceptability of between 35,800 and 42,100 new homes over the plan period and is minded to find that the Core Strategy housing requirement should be expressed as a minimum figure towards the upper end of this range. One relevant aspect, in accordance with the NPPF, is for the Core Strategy to be aspirational but realistic. Setting a housing requirement that is undeliverable may compromise the ability of the Plan to effectively deliver sustainable forms of development supported by adequate Officer Response infrastructure and therefore a housing requirement within this range is proposed.

In the submission draft of the Wiltshire Core Strategy an allowance for 200 homes at the west of Swindon was made that contributed to the overall requirement of 37,000 homes for Wiltshire. Since then a further 700 homes have been permitted on appeal at this broad location. For this reason and in order to be consistent with the submission draft it is therefore considered appropriate to include them within the requirement for 42,000 homes, which is consistent with the findings of the Sustainability Appraisal that indicates up to 42,100 homes is the most sustainable option. This approach was set out in the methodology for disaggregation paper provided to the Inspector in January 2014 (EXAM81).

Paragraph 4.29 clarifies that for the purposes of assessing five year land supply these homes should be counted against Swindon. This position responds to the Ridgeway Farm appeal decision while recognising the relationship of the HMAs and that the housing is being provided in Wiltshire. There is no evidence to indicate that these homes won’t be delivered. Both sites have now commenced development. The Wiltshire Housing Site Allocations Development Plan Document will allocate additional sites to ensure supply across the Plan period. Land at Coate Bridge can be considered through that process.

Consultee Agent Is the Change Mr Tim Baker Mr John Baker legally Yes Comment 543 Strategic Land Partnerships Peter Brett Associates LLP compliant? ID: Is the Change No Person ID: 841158 Person ID: 841162 sound? Positively prepared

Justified Identified proposed Reasons for TPl/15 change unsound Effective

Consistent with national policy Please give details of why you support or (5.13) This should say ‘indicative minimum housing requirement' to ensure consistency across the core strategy document, text and do not support the tables. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) The housing requirements proposed are set as indicative requirements rather than minimum requirements as explained in proposed Officer Response modification to paragraph 4.20 (TPL08).

Consultee Agent Is the Change Mr John Baker legally Yes Comment 612 Waddeton Park Limited Peter Brett Asscoiates compliant? ID: Is the Change No Person ID: 836038 Person ID: 556318 sound? Positively prepared

Justified Identified proposed Reasons for TPL/15 change unsound Effective

Consistent with national policy Please give details of why you support or (5.13) This should say ‘indicative minimum housing requirement’ to ensure consistency across the core strategy document, text and do not support the tables. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The housing requirements proposed are set as indicative requirements rather than minimum requirements as explained in the Officer Response proposed modification to paragraph 4.20 (TPL8).

Consultee Agent Is the Change Mr Mark Simpson legally No Comment 661 Primegate Properties (Hooksouth) Ltd DPDS Consulting Group compliant? ID: Is the Change No Person ID: 836270 Person ID: 556688 sound? Positively prepared

Justified Identified proposed Reasons for TPL15 change unsound Effective

Attached files (Please see Objective) Officer Response See response to comments made on TPL12 under representation number 660.

Consultee Agent Is the Change Mr Mark Funnell legally Comment 157 National Trust compliant? ID: Is the Change No Person ID: 840469 Person ID: sound? Justified Identified proposed Reasons for TBL/16 change unsound Consistent with national policy In response to the need to provide for the 5000 additional homes across Wiltshire, the Amesbury Area Strategy incorporates what the SA Addendum describes as a "sizeable increase" in new housing.

Separately, the Army rebasing programme (see Core Strategy para. 6.23) currently involves an additional 1380 dwellings (1181 new Please give details of build) for service families and 2898 units of single living accommodation*. why you support or do not support the It is questioned whether both can be accommodated within the Amesbury area whilst avoiding adverse effects on the World Heritage consultation material. Site and its setting. The justification (most appropriate strategy..., etc) and consistency with national policy regarding the protection of the historic environment do not appear to be fully demonstrated as things stand. [see also comments on the Sustainability Appraisal]

* Source: MOD consultation documents released February 2014 Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The impact of the Army rebasing proposals have been considered alongside that of the proposed in the Wiltshire Core Strategy. The Officer Response impact of these proposals on the World Heritage Site is a key part of the Overarching Environmental Appraisal for the Army Rebasing Masterplan, which can be reviewed at http://www.army.mod.uk/structure/34026.aspx .

Consultee Agent Is the Change Mrs Margaret Forman Mr Mark Simpson legally Yes Comment 592 DPDS Consulting Group compliant? ID: Is the Change No Person ID: 841247 Person ID: 556688 sound? Positively prepared

Justified Identified proposed Reasons for TPL/16 change unsound Effective

Consistent with national policy Attachment to Representation by Mrs M. Forman Minor Modification to Paragraph 5.12

Representation also relevant to the Inspectors question on National Planning Practice Guidance 2014.

I am concerned that the combined impact of changes to Paragraph 5.12 to increase the flexibility of Core Strategy disaggregation policy could be interpreted as implying the potential to direct larger scale housing growth to inappropriate and unsustainable locations at smaller villages, in event of a failure for development at main settlements to achieve housing delivery requirements of the Core Strategy.

Whilst I do not oppose the flexibility proposed through the potential disaggregation of community area provisions applying to main settlements (eg. to allow housing growth in one main settlement to compensate for lower than forecast growth at another nearby main settlement), it would be unsustainable for such a flexible approach to disaggregation to also be allowed between the requirements Please give details of applying to larger/main settlements and smaller settlements. The potential redirection of growth towards smaller settlements would not why you support or be supported by the Sustainability Appraisal. do not support the consultation material. The maintenance of the distinctive character, environment and social conditions of villages in rural Melksham, in particular the historic village of Broughton Gifford, is of particular importance to achieving objectives of Sustainable Development, and I therefore consider that consequential amendments to clarify the growth requirements are warranted.

While I accept and support the provisions of the Core Strategy to restrict growth in Small Villages to ‘infill' development of up to a few homes, the precautionary principle should be applied to avoiding significant adverse impacts through unsustainable larger scale growth at small rural settlements, predicated by housing shortfalls in main settlements.

An improvement of Core Strategy clarity would also assist in minimising the potential of undesirable ‘planning by appeal'.

Changes are therefore warranted in order to improve the clarity of the Core Strategy for developers and residents alike in accordance with ‘National Planning Practice Guidance - Local Plans' and to ensure that Core Strategy is aligned with the outcomes of the Sustainability Appraisal, which identifies very limited potential for sustainable development at Small Villages, including Broughton Gifford.

I request that the Council amends or introduces new Policy or text that clearly avoids the potential for disaggregation of main settlement housing or employment growth requirements towards rural community areas, specifically the ‘Melksham remainder' area. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The housing provision proposed for each town and community area is now an indicative rather than a minimum level. This deliberately allows flexibility to allow for particular local circumstances. This sets a positive framework for Site Allocations Development Plan Documents (see the Local Development Scheme - Exam 78B) and forthcoming Neighbourhood Plans to work within. They are an indication of the general scale of growth appropriate for each area and key settlements during the plan period. Each increase in housing corresponds to the role and function of each specific town or area relative to all the others in the County and takes into account constraints to growth. This approach provides the best prospects for balanced growth as it reflects the relative economic potential of each settlement as already evidenced in studies and assessments made preparing the Plan and set out in the spatial Officer Response strategy.

Indicative targets therefore provide an adequate balance between providing a level of certainty while also maintaining flexibility, both of which are required by the NPPF.

The level of growth at villages should only be limited in accordance with the requirements of Core Policy 1 and Core Policy 2. Notwithstanding this, the Housing Site Allocations Development Plan Document will identify new housing allocations to ensure that sufficient supply exists across the Plan period and will focus on the main settlements.

Consultee Agent Is the Change Mrs Gillian Ellis-King legally Comment 315 Friends of Woolley compliant? ID: Is the Change

Person ID: 704446 Person ID: sound? Identified proposed Reasons for TPL18 change unsound Bradford on Avon Strategy (para 5.32 onwards)

Please give details of FoW is very concerned about the increase in housing numbers allocated to Bradford on Avon, given the severe infrastructure why you support or problems suffered by the town, however it is accepted that the number allocated is relatively modest, and that the Core Strategy do not support the specifically addresses the phasing of housing delivery. We therefore fully support the retention of policy that states that policy should consultation material. bring forward rebalancing of the town in favour of jobs and that further housing should be phased for delivery throughout the plan period - to allow time for community initiatives on traffic and employment to come forward in advance of further residential development. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Officer Response Comments and support noted.

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 502 Waddeton Park Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 836038 Person ID: 840663 sound? Positively prepared Identified proposed Reasons for TPL18 change unsound Effective Representation TPL18 & TPL19

Waddeton Park Ltd supports the amendments to increase the requirements for Bradford on Avon, which lies within the North and West HMA and within which there is a significant housing land supply shortfall.

In broad terms, Waddeton Park Ltd supports the Council's approach to distributing additional housing requirements. However, as set out in representations to TPL10 and TPL15, additional strategic sites are required. Further, the methodology is relatively crude, and whilst it is a good starting point, positive opportunities to respond to specific issues at some of the Community Areas has not been taken - an assessment of sustainable, deliverable sites at each settlement should be used to further refine the work.

There is safeguarded land to the east of the town, part of which has already been granted planning permission for the development of Please give details of 138 homes (land at Kingston Farm - allocated for 150 dwellings) and part is used as a golf course. In fact, the SHLAA identifies a why you support or number of sites, within and adjacent to the town, which lie outside the Green Belt. The Golf course has capacity for 195 homes do not support the (although there is no evidence that the Council can rely on the availability of this site), whilst the remainder of sites have capacity for consultation material. about 150 homes in total.

The updated delivery table 5.2, shows that capacity for 109 dwellings remain to be identified at Bradford Town. The evidence in the SHLAA, which, in accordance with the NPPG (ID: 3-026-20140306), should be revisited given the housing land supply shortfall, shows capacity for an additional 150 homes without Green Belt review and excluding the Golf course.

There is therefore capacity at the town to deliver more housing, and with the introduction of the Housing Site Allocations DPD, the opportunity to undertake settlement boundary review - and localised Green Belt review - to plan positively for this Core Strategy and the period beyond.

In respect of the latter, this could be undertaken to identify ‘safeguarded land' to replace that which will now be developed. This is a requirement of NPPF paragraph 85. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Support noted.

Officer Response The Wiltshire Housing Site Allocations Development Plan Document will allocate additional sites to ensure supply across the Plan period. Land at the golf course site can be considered through that process. The need to review the Green Belt will be considered as part of a future review of the Wiltshire Core Strategy.

Consultee Agent Is the Change Mr Desmond Dunlop legally No Comment 657 Barratt Homes D2 Planning Limited compliant? ID: Is the Change No Person ID: 392036 Person ID: 558013 sound? Positively prepared

Justified Identified proposed Reasons for TPL18- TPL19 change unsound Effective

Consistent with national policy Barratt Bristol support the identification of Bradford on Avon as a Market Town (See representations to Core Policy 1) which should accommodate a significant level of growth to meet its future needs. However, Barratts do not believe that the level of new housing growth proposed i .e. 150 dwellings is sufficient to do that.

Barratts response in respect of Core Policy 2 Delivery Strategy has raised the concern that the overall level of development proposed is insufficient to meet housing (in particular affordable housing needs) and employment needs in Bradford on Avon in the period up to 2026. In particular, Bradford on Avon has the highest level for affordable housing need particularly for smaller rented affordable properties in the West Wiltshire Area. This level of need is well above average for the West of England Housing Market Area. It means that 57 affordable dwellings need to be built every year but only 48 have been built in the town since 2006. In addition, high house prices and low income means that only 32% of resident households can afford to buy a house in the town based solely on salary. Clearly to propose only 150 new dwellings is inadequate to deal with the acute level of identified need .

Please give details of Barratts control land at Bradford on Avon Golf Course at Avon Close Bradford on Avon which they consider is eminently suitable for why you support or residential development and a new golf course. The site in part is safeguarded to meet the longer terms needs of the area after 2011. do not support the This was recognised by the Local Plan Inspector who conducted the West Wiltshire Local Plan Inquiry. Accordingly, the release of this consultation material. land is considered to be acceptable otherwise it would not have been designated as white land and the issue is when the site will be delivered not if.

Barratts consider that the site is eminently suitable for development and could provide up to 200 dwellings of which 40% would be affordable.

The NPPF sets out guidance for the allocation and release of housing. Sites should be available, achievable and sustainable. The site exhibits all of these qualities as follows:

i) The site is available, achievable and deliverable in line with the guidance in NPPF;

ii) Substantial components of the have high landscape capacity making the area suitable to support a major urban expansion without offending the principle of good Planning;

iii) The development can take place on land outside of the functional floodplain and in line with the guidance in NPPF;

iv) Considerable ecological surveys have been undertaken on the site and are ongoing. A development can be accommodated with a relatively low adverse ecological impact;

v) Development can take place without infringing any areas of archaeological interest;

vi) There are no background noise levels which would be a constraint for development;

vii) All of the requisite utilities can be made available e.g. gas, electricity, water etc. to the development by the usual method of developer funding extensions and reinforcements;

viii) The expansion of the town would not result in the loss of best and most versatile agricultural land;

ix) The development could deal with the existing traffic constraints and problems whilst providing a number of potential improvements e.g. to public transport, infrastructure and the redirection of through and local traffic from the town urban area;

x) The development would provide a range and mix of house types including affordable housing to specifically meet local needs;

In view of the above, the site is eminently suitable for residential development and we recommend that it be identified

Recommendation

i) Identify land at Bradford on Avon Golf Course for residential development. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Comments noted. The Wiltshire Housing Site Allocations Development Plan Document will allocate additional sites to ensure supply across the Plan period. Land at the golf course site can be considered through that process.

The methodology for the distribution of housing across Wiltshire including Bradford-on-Avon is explained in the Addendum to Topic Officer Response Paper 15 Housing Requirements Technical Paper (February 2014). The indicative figures are an indication of the general scale of growth appropriate for each area and key settlements during the plan period. Each increase in housing corresponds to the role and function of each specific town or area relative to all the others in the County and takes into account constraints to growth. This approach provides the best prospects for balanced growth as it reflects the relative economic potential of each settlement as already evidenced in studies and assessments made preparing the Plan and set out in the spatial strategy.

Consultee Agent Is the Change Mrs Gillian Ellis-King legally Comment 317 Friends of Woolley compliant? ID: Is the Change

Person ID: 704446 Person ID: sound? Identified proposed Reasons for TPL19 change unsound CP7: FoW supports that CP7 states that the housing numbers to be delivered should be ‘approximately’ and ‘about’ the figures given, and not ‘at least’ as was previously proposed. This is essential as the policy now gives much greater clarity and control in respect of Please give details of housing numbers and planning applications that may come forward. This is particularly important given the town’s problems relating to why you support or a range of inadequate infrastructure and quality of life impacts from traffic and air quality. do not support the consultation material. We question the deletion of reference to Neighbourhood Planning from policy CP7 as we see that as an essential ingredient in dealing with the identification of non-strategic sites that can deliver the 109 houses yet to find up to 2026.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Support noted. The section referencing neighbourhood planning was part of the monitoring framework which has been removed from Officer Response all policies.

Consultee Agent Is the Change Miss Katherine Dawson legally Comment 505 Waddeton Park Limited Terence O'Rourke Limited compliant? ID: Is the Change No Person ID: 836038 Person ID: 840663 sound? Positively prepared Identified proposed Reasons for TPL19 change unsound Effective Representation TPL18 & TPL19

Attached files (Please see Objective) Officer Response See response to comments made on TPL18 under representation number 502.

Consultee Agent Is the Change Miss Katherine Dawson legally Yes Comment 425 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change Yes Person ID: 840669 Person ID: 840663 sound? Identified proposed Reasons for TPL20 change unsound Representation TPL20 & TPL21

Please give details of Gleeson fully supports the increase in housing requirements for Calne. However, in line with our representations in respect of TPL10, why you support or TPL11, TPL14 & TPL15 we consider that the text should read: do not support the consultation material. "Over the plan period (2006 to 2026), approximately at least 1,605 new homes will be provided, of which about 1,440 should occur at Calne and approximately 165 homes will be provided in the rest of the community area." Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Support noted. See response to comments made on TPL11 under representation number 422 regarding the use of ‘indicative’ (or Officer Response ‘approximate’) figures in the Plan.

Consultee Agent Is the Change Miss Katherine Dawson legally Yes Comment 426 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change Yes Person ID: 840669 Person ID: 840663 sound? Identified proposed Reasons for TPL21 change unsound Representation TPL20 & TPL21

Consultee Agent Is the Change C/O Agent Kevin Goodwin legally No Comment 555 Robert Hitchens Limited CgMs Consulting compliant? ID: Is the Change No Person ID: 841197 Person ID: 841189 sound? Positively prepared

Justified Identified proposed Reasons for TPL21 change unsound Effective

Consistent with national policy TPL21 - Core Policy 8, para 3 this proposes to insert a replacement housing figure for the settlement of Calne. This is derived from Please give details of Table 1. why you support or do not support the Objection has been raised to the number in Table 1 under TPL10. Therefore for consistency objection is also raised to the use of the consultation material. figure of 1440 in this proposed modification. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) See response to comments made on TPL10 under representation number 456 which sets out the Council's response to the Officer Response corresponding issue referred to in the comment.

Consultee Agent Is the Change Unknown Mr Lawrence Turner legally Comment 218 Bloor Homes Barton Willmore compliant? ID: Is the Change

Person ID: 397750 Person ID: 710031 sound? Identified proposed Reasons for TPL22-23 change unsound We separately submitted representations on behalf of our clients in relation to the Chippenham Site Applications DPD scoping consultation. Our clients broadly support the intention of that DPD, however, we make the following observations:

First, we note that a new map identifying broad " strategic areas " for growth at Chippenham has been inserted into the reasoned justification of Core Strategy policy CP10. The addendum to the Core Strategy Sustainability Appraisal (SA) does not appear to provide a justification for the selection of these strategic areas. In light of the Inspector's comments in his tenth procedural letter about the SA, we believe that there needs to be evidence explaining why the proposed strategic areas are justified as the most appropriate strategy and this must be tested through public consultation and independent examination. In the meantime, in order not to delay the adoption of the Core Strategy, the "strategic areas" map should be deleted.

Second, the reasoned justification text to Policy CP10 states that the Chippenham Site Allocations DPD will identify sites to accommodate at least a further 2,625 homes " once existing ... commitments have been taken into account ". In our view, the planning status of larger sites, which are " existing commitments " but do not form historic allocations, should be regularised by their being allocated for residential development and/or the settlement boundaries being re-drawn accordingly. To that end, we are grateful that officers have confirmed that the settlement boundaries for existing commitments in Chippenham will be re-drawn (as part of the Please give details of Chippenham DPD) to include sites such as Hunters Moon within the urban area; however, we consider that there is no reason why this why you support or step should, therefore, be delayed until the adoption of the Chippenham DPD. The Core Strategy policies map should be amended to do not support the include changes to the Chippenham settlement boundary to incorporate Hunters Moon and other similar committed sites within the consultation material. settlement boundary now. Such sites are already being counted by Wiltshire Council as part of their deliverable housing supply, and their allocation and/or amendments to the settlement boundary to incorporate them would further secure their delivery which could otherwise be threatened by changes in planning policy and may be subject to viability issues.

Paragraph 031 (Reference ID: 3-031-20140306) of the recently issued Government Planning Practice Guidance (PPG) confirms that deliverable sites for housing include those allocated in plans and with planning permission, unless there is clear evidence they will not be implemented within 5 years. Unallocated sites without permission may be considered deliverable if there is robust, up to date evidence to support their deliverability and no significant constraints to be overcome. This illustrates the value of allocating sites to firm up their deliverability and, therefore, their ability to be counted as part of the Council's housing supply; and helping the Council ensure the early provision of new homes within the district. The allocation of sites is also supported by the NPPF which, at paragraph 157, states that Local Plans should:

"allocate sites to promote development and flexible use of land, bringing forward new land where necessary..."

The allocation or incorporation within the settlement boundary of existing commitments would also ensure that the updated Core Strategy Policies Map accurately represents the location and scope of existing housing development commitments within the Chippenham area during the plan period. This should facilitate the achievement of the modified Core Strategy wording's aspiration to consider the infrastructure needs generated by new development " cumulatively " (see paraphrased extract from the reasoned justification to Core Policy 10 above).

Finally, in our view, the decision to delay the identification of proposed allocations in Chippenham sits uneasily with paragraph 153 of the NPPF, though we understand it is considered necessary to allow the plan to be adopted. However, the delay means that it is imperative that the Core Strategy provides certainty (through Core Policy 10) as to the timeframe for the preparation of the Chippenham Site Allocation DPD including a clear commitment on the following points:

1. The length of time that the production of the Chippenham DPD will take; 2. The date by which the Chippenham DPD will be formally adopted; 3. The consequences of the Chippenham DPD not being prepared within that timeframe.

In particular, the consequences of failing to meet the deadline for preparation of the DPD must be understood and set out in policy - all parties should be able to see that the adoption of the Core Strategy in the short-term does not take the pressure off achieving a proper long-term robust Plan by a set deadline. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) The broad strategic areas are presented in the supporting text to Core Policy 10, not in the policy itself. An explanation for the diagram is provided in new paragraph 5.54a and 5.54b (Proposed Modification TPL24), including reasons why developing west of the A350 is not considered appropriate. The diagram provides informationabout how the Council intends to proceed based on current knowledge of site availability. Notwithstanding this, a full Sustainability Appraisal will be undertaken as part of the Chippenham Site Allocations Development Plan Document (DPD), which will assess all reasonable alternatives.

The area on the map west of area E was not included because this relates to the Hunters Moon site where there is a resolution to Officer Response grant planning permission for housing and employment and as such is a committed development. The Chippenham Site Allocations DPD will comprehensively review the boundary for Chippenham and consider new planning permissions at that time. It will also consider the cumulative impact of new growth at the town taking into consideration any recent consents.

The updated Local Development Scheme (EXAM 78b) provides a clear timetable for the development of the Chippenham Site Allocations DPD. The DPD is considered the appropriate document to review Chippenham’s settlement boundary in order that it can be carried out comprehensively in a consistent way.

Consultee Agent Is the Change M Adcock legally No Comment 253 compliant? ID: Is the Change No Person ID: 391191 Person ID: sound? Positively prepared

Justified Identified proposed Reasons for TPL22 change unsound Effective

Consistent with national policy I wish to object to the proposal that I have seen for the development of an area from the A4, across Stanley Lane, covering New Leaze Farm and out to the River Marden. This complete area was not in the Core Strategy Plan which was rejected towards the end of 2013. A new plan is not yet in place. Please give details of why you support or Any development which involves large numbers of houses and a considerable expansion of Chippenham needs to be viewed as a do not support the whole. The roadways, shops, schools, medical services, employment prospects and other amenities all need to be considered. consultation material. A piecemeal approach will not be beneficial to Chippenham or the surrounding communities. Any proposals to develop areas outside the original Chippenham Development Plan should not even be considered at this stage. There are brown field sites in and around Chippenham which should be developed first. Consideration should be given to land other than that owned by the council. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Comments noted.

Paragraph 5.47 of the Core Strategy recognises that there are limited opportunities for the redevelopment of brownfield sites in Chippenham and that it will be necessary to identify greenfield sites on the edge of town.

Officer Response The land referred to forms part of the 'Strategic Areas of Search for Chippenham'. At this stage there is not a proposal to build on the land referred to. It is the intention, through the Chippenham Site Allocations DPD to consider this area alongside other areas to determine whether sites within them should be allocated within the Chippenham Site Allocations Development Plan Document, to avoid piecemeal development and plan for Chippenham as a whole.. The DPD will be subject to the full rigours of the plan making process including public consultation, Sustainability Appraisal and independent Examination.

Consultee Agent Is the Change N/A Hansteen Holdings Mr Tim Gent legally Yes Comment 549 Hansteen Holdings PLC Savills compliant? ID: Is the Change No Person ID: 841208 Person ID: 558440 sound? Positively prepared Identified proposed Reasons for TPl/22 change unsound Effective These comments relate to the changes proposed to the plans provisions for Chippenham. The changes are contained principally in TPL/10 and (subject to separate representations) the connected proposals in TPL/13 (Core Policy 2) and TPL/22 (Chippenham Area Strategy). Our comments read as a whole and this text is repeated under each of the representations submitted.

Our primary concern is the proposal to pursue an additional layer of planning guidance for Chippenham (the Chippenham Site Allocations Development Plan Document, which is yet to be prepared but expected for adoption in July 2015).

Our concern is not related to any of the main allocations that may or may not feature in this document, but the position it may leave the town in whilst it is being prepared. Chippenham is one of the primary settlements which will deliver the requirements identified by the Council. As a result we would expect it to identify how and where the town was expected to grow at this stage (as it does everywhere Please give details of else). why you support or do not support the If this position is not correctable, we recommend that the plan makes it clear that some important sites can come forward if they follow consultation material. a clear sequential order (and are clearly accessible, acceptable and sustainable)

Two further changes are proposed to do this:

(a) Introduce a clear statement in to the Strategy that priority will be given to the most sustainable and best located sites in Chippenham (which will generally be in the urban area);

(b) Recognise in the Core Strategy’s text and/or policies that emerging proposals for the most sustainable sites will not be delayed or resisted whilst the Chippenham Site Allocations DPD is being prepared. This approach would allow the Council to accelerate proposals for some sites (within the urban area) whilst more strategic options are considered. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Officer Response See response to comments made on TPL10 under representation number 547.

Consultee Agent Is the Change C/O Agent Kevin Goodwin legally Comment 556 Robert Hitchens Limited CgMs Consulting compliant? ID: Is the Change Yes Person ID: 841197 Person ID: 841189 sound? Identified proposed Reasons for TPL22 change unsound Please give details of TPL22 - Para 5.47/5.47a deals with the Chippenham Area Strategy. It proposes to insert the following text "Strategically important why you support or mixed use sites for the town's expansion will be identified in a Chippenham Site Allocations Development Plan Document. do not support the consultation material. This is supported. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response Support Noted.

Consultee Agent Is the Change Barratt Developments PLC Mr Glen Godwin legally Yes Comment 594 Pegasus Group compliant? ID: Is the Change Yes Person ID: 841252 Person ID: 825048 sound? Identified proposed Reasons for TPL/22 change unsound Barratt support the increase in housing provision at least 42,000 homes, to be delivered in sustainable locations.

Please give details of Barratt are clearly disappointed with the deletion of the strategic allocation at Rawlings Green, Chippenham, which has been why you support or demonstrated to be a sustainable location for growth to partly deliver the strategy for Chippenham. do not support the consultation material. However, the circumstances of this change are understood, following the Inspector's 10th procedural letter, and it is anticipated that an allocation through the Chippenham Area DPD will be given full consideration again in the context of assessing all options. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response Support and comment noted.

Consultee Agent Is the Change Crest Strategic Projects Limited & Redcliffe Mr Desmond Dunlop legally No Comment 652 Homes Ltd D2 Planning Limited compliant? ID: Is the Change No Person ID: 392725 Person ID: 558013 sound? Positively prepared

Justified Identified proposed Reasons for TPL 22- TPL 26 change unsound Effective

Consistent with national policy Crest and Redcliffe are generally supportive of the Wiltshire and Chippenham Area Strategy in particular. They believe that development to the South of Chippenham has the potential to make a significant contribution to the strategy, objectives and overall vision for Chippenham. Furthermore, the site is deliverable in the plan period unlike other competing sites such as to the East.

The Core Strategy recognises the key challenges for Wiltshire over the next 15-20 years. Providing jobs locally and promoting the economic growth of Wiltshire is a significant challenge given the size and rural nature of the County. Chippenham has a big role to play in generating jobs locally and taking advantage of Wiltshire's position in the prosperous northern part of the South West region. Land south of Chippenham at Showell Farm has been identified for large scale employment development and can help to make a significant contribution to Wiltshire's economy moving forward. Furthermore it benefits from a resolution to grant planning permission for employment development and the Secretary of State has recently withdrawn a holding direction to allow the Council to grant planning permission. Please give details of This applies not only to the creation of employment land but also to the delivery of housing, also recognised as a key challenge. If why you support or housing supply is not able to match local demand, it is younger and more vulnerable members of Wiltshire's existing community that do not support the will find it difficult to afford house prices or rents. This will put strain on local social housing or force younger people to leave the area consultation material. they grew up in. Development of housing as identified in south of Chippenham next to the employment land is clearly the most sustainable way of accommodating this housing growth and adapting to minimise the future impact on climate change.

The promoters strongly advocate that development at Rowden and Patterdown and Showell Farm has the potential to add the greatest benefit for existing residents of Chippenham that are unique to the south. Through the retention and creation of jobs in the town, through the enhancement of a significant environmental and informal leisure area in the River Avon Corridor green park and by providing better walking and cycling links to Lackham College helping to draw it into the town.

Allied to opportunities to provide new walking, cycling and public transport links to Chippenham Town Centre, development south of Chippenham can make the most of Chippenham's existing transport infrastructure, improving it as necessary and avoiding significant road building projects which would require significantly higher levels of growth to be viable i.e. to the east. This will release planning obligations for social, green and environmental on site facilities, which could otherwise be tied up in delivering very expensive enabling infrastructure.

Land south west of Chippenham clearly represents the best option for expanding Chippenham that is most sustainable, deliverable and capable of providing benefits for existing communities whilst meeting the objectives of the draft Core Strategy. The options to the east are not as sustainable and rely on providing major infrastructure provision which cannot be delivered within the plan period.

Accordingly whilst Crest/Redcliffe believe that the assessment of all strategic sites should have taken place as part of the Core Strategy, it is apparent that Patterdown/Rowden and Showell Farm meet all of the identified criteria in amended Core Policy CP1O:-

1. The site can be delivered within the plan period. It is controlled by 2 experienced housing and employment developers and Showell Farm already benefits from a resolution to grant planning permission.

2. The site has the capacity to provide a range and mix of house types including market and affordable housing and does not require expensive new infrastructure to aid delivery. The site can utilise existing infrastructure which has been planned to be upgraded to accommodate future development.

3. The local road network can accommodate the traffic from the proposed development because it has been planned to be upgraded as and when additional development is needed.

4. The site has excellent accessibility to a range of facilities including the town centre. Indeed a proper comparative assessment of its accessibility credentials in respect of other sites e.g. to the east reveals that it is more sustainable.

5. A detailed landscape and visual impact assessment has been carried out (unlike other sites). This reveals that the landscape has a high capacity to absorb development.

6. Development can take place within Flood Zone 1 and provide all the necessary surface water management provision.

Crest/Redcliffe believe that the land at Rowden/Patterdown and Showell Farm provides an excellent opportunity to provide strategic development to Chippenham. The site is not constrained unlike others and can be delivered within the plan period. However, Crest/Redcliffe remain concerned that the criteria specified in CPlO do not represent a list of criteria best suited for the identification of strategic sites. They essentially relate to a set of generic criteria which all sites can meet to a large degree. Crest/Redcliffe have already made the Council aware of their concerns at the recent Developer's Forum. They believe that site promoters should provide evidence on the deliverability of their site within the Plan period.

Recommendation i) Identify strategic sites for Chippenham as part of Wiltshire Core Strategy not the Chippenham Site Allocation DPD; ii) The criteria in Core Policy 10 should not be used to identify strategic sites for Chippenham; and

iii) Ensure that the allocation of strategic sites is based on the actual deliverability of the site within the Plan period. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) General support for the overall strategy noted.

The Council has committed to preparing the Chippenham Site Allocations Development Plan Document (DPD) in response to the Inspector's concerns raised in the 10th Procedural Letter to ensure the fair and equitable assessment of all sites at the town. This commitment is included in the Local development Scheme which identifies a challenging timetable to reduce delay in the delivery of strategic sites at Chippenham. Officer Response The criteria suggested within Core Policy 10 are intended to provide the basis to guide the allocation of sites and to provide guidance should sites be promoted in advance of the Chippenham DPD. The removal of the criteria would remove any guidance on how to consistently appraise sites/applications. .

Deliverability of sites during the plan period will be a key test for any DPD (which is reflected in criteria 1 and 2) and will form part of its examination.

Consultee Agent Is the Change Mr George McDonic legally No Comment 691 CPRE Wiltshire compliant? ID: Is the Change No Person ID: 700158 Person ID: sound? Justified Identified proposed Reasons for TPL22 change unsound Effective Chippenham Area Strategy [CP1, 4.26c, 5.44 et seq.] Widespread and acknowledged areas of uncertainty strip the meaning out of the Core Strategy plans for Chippenham. The Core Strategy is unclear on: (a) housing requirement (exceptionally expressed in 4.26c simply as a minimum); (b) requirements for and financial viability of development infrastructure; (c) selection of strategic development Please give details of areas and assessment of associated flood risk. The development templates for Chippenham are now simply removed in entirety from why you support or Appendix A. do not support the consultation material. In effect the entire strategic development of Chippenham is being left for a parallel DPD to decide, and as a result the Core Strategy lacks a coherent strategy for its third most important settlement. It is questioned whether this omission can really be treated as trivial or routine, or whether in fact it undermines the soundness of the Core Strategy.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) The core strategy continues to provide clear strategic advice on the strategy for Chippenham and the scale of growth at the town.

Officer Response The Chippenham Site Allocations Development Plan Document will have equal weight to the Wiltshire Core Strategy as a part of the development plan. Core Policy 10 provides strategic policy to inform the preparation of the DPD and identifies Chippenham as a broad location for strategic development.

Consultee Agent Is the Change Mr George McDonic legally No Comment 692 CPRE Wiltshire compliant? ID: Is the Change No Person ID: 700158 Person ID: sound? Justified Identified proposed Reasons for TPL23 change unsound Effective Chippenham Area Strategy [CP1, 4.26c, 5.44 et seq.] Widespread and acknowledged areas of uncertainty strip the meaning out of the Core Strategy plans for Chippenham. The Core Strategy is unclear on: (a) housing requirement (exceptionally expressed in 4.26c simply as a minimum); (b) requirements for and financial viability of development infrastructure; (c) selection of strategic development Please give details of areas and assessment of associated flood risk. The development templates for Chippenham are now simply removed in entirety from why you support or Appendix A. do not support the consultation material. In effect the entire strategic development of Chippenham is being left for a parallel DPD to decide, and as a result the Core Strategy lacks a coherent strategy for its third most important settlement. It is questioned whether this omission can really be treated as trivial or routine, or whether in fact it undermines the soundness of the Core Strategy.

Attached files (Please see Objective) See response to comments made on TPL22 under representation number 691. Officer Response

Consultee Agent Is the Change Mr Tony Peacock legally Yes Comment 86 The Showell Protection Group compliant? ID: Is the Change No Person ID: 395460 Person ID: sound? Positively prepared

Identified proposed Reasons for TPL24 Justified change unsound

Effective TPL24 proposes that new paragraphs under the heading of Strategic Approach to New Development in Chippenham Core policy 10.

One proposed paragraph includes “... broad ‘strategic areas’ for growth and indicated by barriers to growth such as main roads, rivers and the main railway line”. The Showell Protection Group notes the only place the railway line currently forms a barrier for the town is Please give details of to the north/north west of Showell Farm. why you support or do not support the The railway line has previously been clearly identified by Planning Inspectors as forming the natural boundary of the town. consultation material. The Showell Protection Group believes this should be maintained and no development south of this section of the railway line should be allowed.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) Comments noted.

The proposed modification (TPL24) refers to several “barriers such as main roads, rivers and the main railway line” in explaining how the areas of search have been identified. It continues to state that 'the A350 is one such barrier to development, but is also considered to be a clear and logical barrier to the town, which should not be breached unless other options are exhausted”. The A350 is therefore Officer Response a clear and logical boundary to Chippenham, however as the railway line travels through Chippenham the boundary is not so definitive.

The purpose behind defining strategic areas is to help inform the selection of strategic mixed use development sites at the Town. There will be public consultation and examination of any future proposals proposed through the Chippenham Site Allocations Development Plan Document.

Consultee Agent Is the Change Mr Tony Peacock legally Yes Comment 87 The Showell Protection Group compliant? ID: Is the Change No Person ID: 395460 Person ID: sound? Positively prepared

Identified proposed Reasons for TPL24 Justified change unsound

Effective TPL24 proposes that new paragraphs under the heading of Strategic Approach to New Development in Chippenham Core policy 10.

One proposed paragraph states: “These broad ‘strategic areas’ for growth are indicated by barriers such as main roads, rivers and the main railway line. The A350 is one such barrier to development, but is also considered to be a clear and logical boundary to the town, which should not be breached unless other options are exhausted. Hence no strategic areas are shown west of the A350. The Chippenham Site Allocations DPD will assess how each of these areas performs against criteria contained in Core Policy 10”. Please give details of why you support or Whilst the Council planners seem happy to ignore the railway boundary with the a recommendation for an employment site south of do not support the the railway at Showell Farm they seem content to use the A350 as a western boundary of the town despite the fact that there has consultation material. already been development to the west of the A350 with the construction of a major care and retirement home and a major expansion of an existing budget hotel.

The planners are also being disingenuous about development to the west of the A350 in that it is known that they are currently in discussion with a developer for a major ‘occupier led’ development to the west of the A350 on a site capable of taking all of the required 18.5 hectares of strategic employment land designated for Chippenham. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) See response made to other comment on TPL24 in representation number 86.

Officer Response The area to the west of the A350 referred to relates to a discrete part at the northern end of the town. The other significant section of the A350 around the built up area of the town forms a clear boundary.

Consultee Agent Is the Change Dr Bret Palmer legally Yes Comment 124 compliant? ID: Is the Change No Person ID: 840026 Person ID: sound? Identified proposed Reasons for TPL 24 and 25 Consistent with national policy change unsound It is my understanding that Wiltshire Council should draw up a core strategy which is consistent with national policy and that the core strategy will outline a sustainable spatial strategy for future development in the county and include:

1. key principles of development 2. the location of strategic sites for new housing and employment development 3. policies with which planning applications will be assessed 4. a key diagram displaying the spatial aspects of the core strategy

The planning inspectors' changes are mainly due to outcomes of the sustainability appraisal which cannot withstand scrutiny as an Please give details of evidence source which assists in justifying the content of the core strategy. Failure for Chippenham to be part of the core strategy will why you support or increase the risk of long term unplanned building, which would then damage any long term plans the County or Town councils may do not support the have for Chippenham. consultation material. As all of the strategic allocations of Core Policy 10 have been removed for Chippenham under the proposed modifications (TPL 24 & TPL 25), and this is all due to a failure of Wiltshire county council in submitting a robust sustainability appraisal. I would suggest that Wiltshire Council either repeats the sustainability appraisal or gains an assurance from the planning inspector, that the allocations identified in Chippenham by the Chippenham Site Allocations Development Plan Document, will have as much legal standing as the remaining core strategy in the County and Town Councils ability to refuse planning applications that do not meet the councils master plan for housing in Chippenham.

Regards Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The Chippenham Site Allocations Development Plan Document (DPD) will have equal weight to the Wiltshire Core Strategy as part of the development plan for Wiltshire. The Council has committed to the preparation of the DPD and is aiming to publish the draft DPD for Officer Response consultation Autumn 2014. Core Policy 10 provides strategic policy to inform the preparation of the DPD.

A new full Sustainability Appraisal will be undertaken as part of the Chippenham DPD process.

Consultee Agent Is the Change Mr Kim Stuckey legally Yes Comment 196 compliant? ID: Is the Change No Person ID: 375804 Person ID: sound? Positively prepared

Identified proposed Reasons for Justified change unsound

Effective Chippenham is the only town where a minimum amount of development is given. If at this stage of the Core Strategy preparation, after thousands of pages of documentation, either the Council or Inspector or both cannot agree on a figure for development of Chippenham it demonstrates the unsoundness of the complete process.

I cannot contemplate how the strategy can state ".. broad ‘strategic areas’ for growth are indicated by barriers such as main roads, rivers and the main railway line.The A350 is one such barrier to development, but is also considered to be a clear and logical boundary to the town,which should not be breached unless other options are exhausted." However the development should "...Has an acceptable landscape impact upon thecountryside and the settings to Chippenham and surrounding settlements, improves biodiversity and access to the countryside". So the Inspector is allowing a statement that a natural environment of a river should be breached as a boundary before a main road. This demonstates the unsoundness of the plan.

The strategy states "Currently, the limited opportunities for the redevelopment of brownfield sites inChippenham means that it is necessary to identify greenfieldsites on the edge of town." This is ridiculous when brownfield development at Langley Park in the Please give details of centre of town is slated for a supermarket rather than housing, no consideration of a Junction 17 business park with sustainable why you support or transport links to town has been made - whioch would free up land at Bumpers Farm and other business parks. These are just some do not support the examples of where narrow thinking of individual developments rather than a holistic approach to the Core Startegy has made the consultation material. whole process and document unsound.

It alos appears that the Inspector hasd taken no consideration for the previous huge opposition to building east of the River Avon. As I commented at that time "this option scores negatively in the sustainability report on the most worrying area of flooding, but also air quality and pollution, climatic factors and transport. There are also some glaring missing areas in the sustainability report, especially the impact on the landscape for the preferred option, with the landscape impact on the Avon Valley and the destruction of the Marden River Valley and the impact on HE1 areas such as Tytherton Lucas. How a conclusion can be reached with so little research is a damning indictment of the whole project.The whole concept of sustainable development in this plan is gated on the fact that the building of 3,500 new homes will attract the employment opportunities for an additional 6,000 or so people of working age. If this fails to happen the Council will have delivered the complete opposite of sustainable development – the provision of a new dormitory town for Swindon, Bath and Bristol with a huge environmental impact on road and rail travel.The section talks about “provision of housing and employment close to the railway station”. The housing is not in fact close to the railway station at all (except as the crow flies), it would only be accessible via going up to a link road spur through the Monkton Park estate. This also demonstrated the isolation of the new development yet again. What additional parking facilities would be provided at the station to cope with the potential large volume of additional people wishing to commute from Chippenham." Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) The scale of housing requirement for Chippenham is expressed as a minimum reflecting the further work needed to identify a pattern of development that can best utilise the town’s economic potential and provide strategic infrastructure that may be required. This work will be undertaken through the Chipenham Sites Allocations Development Plan Document (DPD). The level of greenfield sites to be provided at the town should be deliverable within the plan and will be subject to the full rigour of the plan making process including public consultation, Sustainability Appraisal and independent examination.

It is considered that Chippenham has an economic potential that has not been reflected in recent rates of housing development. The allocation of strategic sites will provide much needed land for employment development which will help to improve the town’s economic base and reduce the proportion of net out-commuting which represents a better consequence that might otherwise occur. In so doing a pattern of development can be produced which ensures the most valuable green space around Chippenham, such as the River Avon Officer Response corridor, is protected. At this stage there is no proposal for development on specific areas of land at Chippenham. It is the intention, through the Chippenahm Site Allocations DPD to assess all strategic areas. The criteria proposed in CP10 will be used to guide this process and include criteria to ensure valued greenspace and areas liable to flood are protected.

The amendment to TPL24 indicates several barriers such as main roads, rivers and the main railway line exist and continues to state that 'the A350 is one such barrier to development, but is also considered to be a clear and logical boundary to the town, which should not be breached unless other options are exhausted’ However as the railway line travels through Chippenham the boundary is not so definitive. The purpose behind defining strategic areas around barriers to development is for the selection of strategic mixed use development sites. A review of Chippenham settlement boundary will be carried out separately as a part of preparing the Chippenham Site Allocations DPD.

Consultee Agent Is the Change Miss Katie Sprackman legally Yes Comment 203 Hallam Land Management compliant? ID: Is the Change No Person ID: 840626 Person ID: sound? Positively prepared

Identified proposed Reasons for TPL/24 Justified change unsound

Consistent with national policy We only consider this section unsound in the context of our representations on TPL13 and overall numbers, as meeting the objectively assessed need in full would likely result in Chippenham requiring higher numbers. However, if the 42,000 is found sound and taken forward by the Inspector we have the following comments to make.

We support the Inspectors recommendation in his letter dated 2 nd December 2013, that the Council are to review their approach to development allocations within Chippenham, and we will look forward to contributing to the production of the Chippenham Site Allocations document. Please give details of why you support or We believe that there are a number of areas throughout the County that could accommodate development to achieve a housing figure do not support the closer to the objectively assessed need, one such place being Chippenham. We attach a plan showing a potential development area consultation material. and whilst site will be considered through the DPD rather than this Core Strategy, we hope it is helpful to the Council to supplement the data and information it is currently gathering to inform the DPD process. The site is in the southwestern part of the town and could form an extension of 400-500 dwellings to the area previously identified as a preferred direction of growth.

With this in mind Hallam strongly support the Councils suggestion that instead of an ‘indicative requirement’, provision should be set at a ‘minimum’ housing figure for Chippenham to ‘’provide the flexibility to allocate sites that can most effectively articulate the most sustainable pattern for the town’s long term growth’’.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) Officer Response Support noted. See response to comments made on TPL13 by representation number 201.

Consultee Agent Is the Change Miss Katie Sprackman legally Yes Comment 227 Hallam Land Management compliant? ID: Is the Change No Person ID: 840626 Person ID: sound? Positively prepared

Identified proposed Reasons for TPL/24 Justified change unsound

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please Chippenham Illustrative Masterplan see Objective) Officer Response Support noted. See response to comments made on TPL13 by representation number 201.

Consultee Agent Is the Change Mrs Andrea Doel legally Yes Comment 297 compliant? ID: Is the Change No Person ID: 840550 Person ID: sound? Justified Identified proposed Reasons for TPL/24 change unsound Consistent with national policy The proposal to allow houses to be built on the New Leaze Farm site is flawed. Last year saw increased flooding in that area and the adjoining area of Tytherton Lucas and East Tytherton and a number of properties, previously not felt to be at risk of flooding, came within five centimeters of being flooded. Additional properties will significantly increase this risk. To ignore this extremely high risk of damage to people's properties, the associated suffering of those home owners and the resultant compensation claims against the council would be wrong. Please give details of why you support or The proposed development is not even in Chippenham and should be excluded from that plan. It's in the parish of Bremhill and subject do not support the to a neighborhood plan that supports the rural development appropriate to, and in keeping with, the parish. In fact, we have have been consultation material. advised that this area is a highly valued Wiltshire landscape that should be protected under Core Policy 51 with the equivalent of a rural buffer zone.

Please don't spoil this beautiful landscape and ruin the lives of the people of Bremhill parish.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The allocation of strategic sites at Chippenham is the focus for the Chippenham Site Allocations Development Plan Document (DPD) and will consider sites adjacent to the continuous urban area of the town, which includes land within the adjoining Bremhill Parish.

The land referred to at New Leaze Farm forms part of the 'Strategic Areas of Search for Chippenham' and will be considered alongside Officer Response other areas to determine whether sites within them should be allocated within the DPD following a fair and equitable consideration of all the alternatives. The criteria suggested within Core Policy 10 are intended to provide the basis to guide the allocation of sites in the DPD and include criteria relating to flooding and landscape. The DPD will be subject to the full rigours of the plan making process including public consultation, Sustainability Appraisal and independent Examination.

Consultee Agent Is the Change Mr John Boldon legally Comment 393 Lacock Parish Council compliant? ID: Is the Change

Person ID: 840882 Person ID: sound? Identified proposed Reasons for TPL24 change unsound TPL 24 has been included " to reflect the removal of sites " from the Core Strategy. It goes on to state that the growth targets will be met through the identification of new sites in the Chippenham Site Allocations DPD. It further indicates through the following paragraph that certain physical barriers will determine where the growth areas should be.

"These broad ‘strategic areas' for growth are indicated by barriers such as main roads, rivers and the main railway line.

The A350 is one such barrier to development, but is also considered to be a clear and logical boundary to the town, which should not be breached unless other options are exhausted. Hence no strategic areas are shown west of the A350. The Chippenham Site Please give details of Allocations DPD will assess how each of these areas performs against criteria contained in Core Policy 10." why you support or do not support the consultation material. Lacock Parish Council finds it inexplicable why Wiltshire Council accepts that the A350 is a barrier to development and a logical boundary to the town and yet the major embankment on which the main railway line is located to the south of Chippenham is not. This is a most inequitable approach and defies logic especially when development is being allowed to the west of the A350 for the development of a care home etc near to where the new dualling of the A350 is taking place.

In choosing to adopt this approach Wiltshire Council is choosing to ignore several decisions of Planning Inspectors both in hearing Planning Appeals and in making recommendations on the North Wiltshire Local Plan when they came out against proposed development to the south of the main railway line at Showell Farm.

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) The proposed modification (TPL24) refers to several “barriers such as main roads, rivers and the main railway line” in explaining how the areas of search have been identified. It continues to state that 'the A350 is one such barrier to development, but is also considered to be a clear and logical barrier to the town, which should not be breached unless other options are exhausted”. The A350 is therefore a clear and logical boundary to Chippenham, however as the railway line travels through Chippenham the boundary is not so Officer Response definitive.

The purpose behind defining strategic areas is to help inform the selection of strategic mixed use development sites at the Town. The area to the west of the A350 referred to relates to a discrete part at the northern end of the town. The other significant section of the A350 around the built up area of the town forms a clear boundary.

Consultee Agent Is the Change Mr John Boldon legally Comment 396 Lacock Parish Council compliant? ID: Is the Change

Person ID: 840882 Person ID: sound? Identified proposed Reasons for Appendix C - Strategic Areas of search for Chippenham change unsound Lacock Parish Council fails to understand why Wiltshire Council is choosing to be selective in it's approach to determining the need and location of potential growth areas. As mentioned above it is felt that the Council is being inequitable in choosing to define the A350 as a physical barrier to development and yet the main railway line defining the northerly limit of the Showell Farm site is not. Please give details of why you support or It further considers that Wiltshire Council is choosing to ignore the fact that the Hunters Moon site is likely to be permitted for housing do not support the and that a major employment site has been permitted to the south east of Junction 17 of the M4 Motorway. consultation material. It can only conclude that by excluding these sites it helps Wiltshire Council justify the strategic areas it is to consider in the Chippenham Site Allocations DPD. Lacock Parish Council disagrees with this approach. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) See response to comments made on TPL24 under representation number 393.

Officer Response In addition, the Hunters Moon site has a resolution to grant planning permission for housing and will contribute towards delivery of the requirement in Core Policy 10. This land between the railway and the A350 is not identified as a strategic area because it is viewed as a commitment rather than a potential new allocation. There is no planning application at Junction 17 for employment development.

Consultee Agent Is the Change Miss Katherine Dawson legally Yes Comment 427 Gleeson Developments Limited Terence O'Rourke Limited compliant? ID: Is the Change Yes Person ID: 840669 Person ID: 840663 sound? Identified proposed Reasons for TPL24 change unsound Gleeson fully supports the approach to and increase in housing requirements for Chippenham.

In order to provide flexibility and address the issue of sustainable development, it is important that the boundaries of the town are revisited in full. There will be opportunities for early delivery and for longer term delivery and these need to be considered fully, particularly in relation to the contribution that the Chippenham sites are able to make to the five year housing land supply and in the identification of developable sites to help meet the 6 - 10 year supply.

Please give details of In order to plan positively and meet this need for early delivery it is important that the policy does not impose unjustified burdens on the why you support or process to be followed. It is not entirely clear what is expected by the following amendment: do not support the consultation material. "Sites that do come forward should be the subject of a partnership between the private and public sector based on frontloading with a master plan to be approved by the Local Planning Authority as part of the planning application process. This master plan will guide the private sector led delivery of the site."

Clearly pre-application discussions will be important and the development of a master plan for each site, with input from officers. Further the master plan for each site should not preclude the development of any adjacent sites, or seek to impose third party land ownership issues which could frustrate development. However, as drafted this amendment does not set out clearly what in intended and how the process will work. It is therefore ineffective. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

Attached files (Please see Objective) Support noted. The quote from policy is referring to the role of master plans in planning for the sites identified in accordance with Core Officer Response Policy 10. This is consistent with the requirement in Core Policy 2 for the allocations identified in the Core Strategy which has always been part of the delivery process for allocated sites.

Consultee Agent Is the Change C/O Agent Kevin Goodwin legally Comment 557 Robert Hitchens Limited CgMs Consulting compliant? ID: Is the Change Yes Person ID: 841197 Person ID: 841189 sound? Identified proposed Reasons for TPL24 change unsound Please give details of TPL24 - Appendix C - this shows the ‘Strategic Areas of Search for Chippenham'. why you support or do not support the This is supported consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response Support noted.

Consultee Agent Is the Change C/O Agent Kevin Goodwin legally No Comment 558 Robert Hitchens Limited CgMs Consulting compliant? ID: Is the Change No Person ID: 841197 Person ID: 841189 sound? Positively prepared

Justified Identified proposed Reasons for TPL24 change unsound Effective

Consistent with national policy TPL24 - Para 5.54a/5.54b and 5.54c this suggests "new paragraphs under the heading Strategic Approach to New Development in Chippenham Core Policy 10 identifies a need to identify at least a further 2625 dwellings (once existing completions and commitments have been taken into account) and 26.55ha of land for employment development on land adjoining the built up area. The Chippenham Site Allocation DPD will identify mixed use land opportunities necessary to deliver at least this scale of growth. In this context there are a number of strategic areas where large mixed use sites could be located and directions for growth are shown diagrammatically below:

Objection: This figure is based upon two assumptions. Firstly that the overall housing trajectory number is correct and secondly that the methodology to reach the residual figure is correct.On the first point we have raised an objection to the figure of 42,000 proposed by the Council and suggested that this should be 44,000.

Please give details of On the second point the figure ‘at least a further 2625 dwellings' appears to have been based upon a disaggregation of the overall why you support or housing number between settlements within each HMA. In this respect Topic Paper 15 addendum - Housing Requirement Technical do not support the Paper (Exam 84) provides various scenarios for each settlement and in respect of Chippenham whilst a figure of 4510 is chosen the consultation material. re-proportioned requirement is stated at 4629 dwellings in the table at the end of the document.In the header to the columns in the table the question as to whether the figure that precedes it is ‘is this less than double historic rates'. In respect of a number of settlements including Chippenham the answer is ‘No'. With the

exception of Chippenham the disaggregated figure is carried forward to the ‘final requirement' unchanged.

However in the case of Chippenham the figure is reduced by 119 dwellings to 4510. It is then this figure that is rolled forward into Appendix 4 of the Housing Land Supply Statement (Exam 91). This figure presumably underlies the figure of 2625 here and may well show a shortfall of 119 dwellings.

Therefore objection is raised to this figure.

Attached files (Please see Objective) See response to comments made on TPL10 under representation number 456.

The Addendum to the Housing Topic Paper (EXAM84) sets out a number of key tests to ensure that the disaggregation of the revised Officer Response housing figure is realistic taking into account environmental constraints and historic delivery rates. As set out in the table in EXAM84 the re-proportioned figure for Chippenham represented over double the historic delivery rate at the town which was considered unrealistic and was adjusted accordingly.

Consultee Agent Is the Change Barratt Developments PLC Mr Glen Godwin legally Yes Comment 596 Pegasus Group compliant? ID: Is the Change Yes Person ID: 841252 Person ID: 825048 sound? Identified proposed Reasons for TPL/24 change unsound Barratt support the broad strategic areas of growth and have previously submitted a significant level of detail to support the sustainability and deliverability of 700 houses and 6 hectares of employment in strategic area C. it is clearly important that the strategic Please give details of guidance set out in paragraphs 5.54a-c needs to ensure that the process of allocating sites through the Chippenham Area DPD deals why you support or with all reasonable options "in a fair and comparable manner", having regard to the Inspector's Comments in his 10th procedural letter do not support the and the Council's obligations in respect of due process of the Sustainability Appraisal. consultation material. Barratt support the text relating to Core Policy 10 criteria and have previously demonstrated that the Rawlings Green site allocated in the pre-Submission draft would be able to deliver growth and cumulatively address strategic infrastructure issues for the town. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response Support noted.

Consultee Agent Is the Change Mr George McDonic legally No Comment 693 CPRE Wiltshire compliant? ID: Is the Change No Person ID: 700158 Person ID: sound? Justified Identified proposed Reasons for TPL24 change unsound Effective Please give details of why you support or This consultee has registered this comment against multiple modifications. Please see comment 691 under TPL22 for the full do not support the representation. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Officer Response See response to comments made on TPL22 under representation number 691.

Consultee Agent Is the Change Cllr Chris Caswill legally Yes Comment 84 compliant? ID: Is the Change No Person ID: 466775 Person ID: sound? Positively prepared

Identified proposed Reasons for Appendix c, p 84 Justified change unsound

Effective Please give details of The map of Chippenham on p 84 is not fit for purpose. The areas A-E are not properly defined. This appears to be a re-hash of an old why you support or North Wilsthire DC document. Its lack of clarity only adds to the uncertainty generated by the minimum allocation proposals. It should do not support the be withdarwn and resubmitted with better definition as part of a revised TPL 10. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Consultee Agent Is the Change Mr Tony Peacock legally Yes Comment 88 The Showell Protection Group compliant? ID: Is the Change No Person ID: 395460 Person ID: sound? Positively prepared

Identified proposed Reasons for Appendix C - Strategic Areas of Search for Chippenham. Justified change unsound

Effective Appendices to Schedule of Proposed - Modifications in response to 10th Procedural Letter

Appendix C - Strategic Areas of Search for Chippenham.

Please give details of The decision to exclude the Hunters Moon site at Chippenham within the Strategic Areas for Search for Chippenham defies logic. why you support or do not support the At the meeting of the Wiltshire Council Strategic Planning Committee (the clue is in the name!) held on the 22nd January, 2014 the consultation material. Committee approved an outline planning application for the construction of up to 450 homes on the Hunters Moon site. To not include these in the proposed strategic allocation of 2,625 dwellings is perverse effectively means the construction of over 3,000 new dwellings, well above the requirements of the town as identified by the Planning Inspector.

The Showell Protection Group believe Hunters Moon should be included in the strategic area of search for Chippenham. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The Hunters Moon site has a resolution to grant planning permission for housing and will contribute towards delivery of the Officer Response requirement in Core Policy 10, as such it is viewed as a commitment and is already removed from the residual requirement for 2625 homes at Chippenham.

Consultee Agent Is the Change Mr Tony Peacock legally Yes Comment 89 The Showell Protection Group compliant? ID: Is the Change No Person ID: 395460 Person ID: sound? Positively prepared

Identified proposed Procedural Letter - Appendix C - Strategic Areas of Search for Reasons for Justified change Chippenham unsound

Effective Procedural Letter - Appendix C - Strategic Areas of Search for Chippenham.

There is a significant lack of ‘joined up’ planning amongst the bodies determining the future development of Chippenham.

In the consultations leading up to the draft Core Strategy, Wiltshire Council consistently refused to consider employment land development taking place to the north of Chippenham along the A350 up to Junction 17 of the M4.

The recently published Swindon and Wiltshire Local Enterprise Partnership ALIGNING LOCAL INNOVATION WITH GOVERNMENT Please give details of AMBITION Strategic Economic Plan March 2014 states: “The area north of Chippenham up to where the A350 meets the M4 why you support or Motorway has the potential to develop a number of sites for new employment facilities which would be highly attractive to high tech do not support the firms looking to be part of the M4 Corridor”. consultation material. It is clear that the road to the north of the town WILL be an area for major employment development in the future. It is bemusing that strategic development is not being considered in this area.

It is further noted that outline planning permission has already been agreed by the Wiltshire Strategic Planning Committee for housing development at Birds Marsh immediately adjacent to the A350 north of the town increasing the sustainability of any employment land development to the north.

The strategic area of search should be extended north of the town to encompass strategic land along the A350. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) The purpose behind defining strategic areas is for the selection of strategic mixed use development sites to meet the housing and employment needs of Chippenham. Sites for employment need to be indentified that provide opportunities for indigenous businesses Officer Response and entrepreneurs to develop and grow from start up to large scale The reference to the potential at motorway junctions by the LEP relates to the attraction f footloose, inward investment. There is a role for all forms of employment but the Chippenham Site Allocations DPD is focusing on the housing and employment needs of Chippenham which is reflected in the strategic areas identified in the diagram. Other policies of the core strategy respond to employment opportunities outside of main settlements (CP34)

The A350 is a clear and logical boundary to Chippenham. Hence no strategic areas are show west of the A350. Equally, the outer limit of strategic areas has also not been defined. The Chippenham Site Allocations DPD will consider such issues when allocating specific sites in coming to proposals for the most sustainable pattern for the town's long term growth following an assessment of the strategic areas.

Consultee Agent Is the Change Mrs Helen Stuckey legally Yes Comment 177 compliant? ID: Is the Change No Person ID: 840547 Person ID: sound? Effective Identified proposed Reasons for TPL/25 change unsound Consistent with national policy TPL/25 sets out, under Core Policy 10, six criteria for evaluating the revised site allocations for Chippenham. These 6 criteria are extremely high level and I have not seen the final Chippenham Site Assessment Framework which should provide more detail. From what has been provided so far several aspects are "unsound" as follows:

Criterion 1 re "employment development" - this is absolutely critical if we are to avoid adding evermore commuters and consequent traffic to the population of Chippenham. However, employment isn't simply a matter of "delivery of premises". The potential for different sectors and their requirements e.g. transport, skilled workers, broadband , etc needs to be fully understood and provided, before approval is given for building homes.

Criterion 2 re "delivery of facilities and infrastructure". Before approving any developments, Chippenham needs a detailed plan of the additional facilities and infrastructure required to support a much larger population. Some of these items will be very expensive and an appropriate CIL will need to be levied across all new developments to ensure sufficient funding is raised to put all of the necessary facilities and infrastructure in place. Please give details of why you support or Criterion 3 re "traffic access" and "traffic impacts". Chippenham is already gridlocked in the rush hour. The A350 ring road needs to do not support the be duelled all the way around Chippenham. The A4 needs a Southern bypass to avoid the current jams around the south of the town consultation material. centre. Any new housing developments should avoid contributing to the gridlock around the town centre and should have direct access to the primary route network. Careful consideration should be given before any further facilities are developed in the centre of Chippenham e.g. new offices, additional shopping areas, etc as these will only exascerate the traffic problems. Alternative out of town sites should be adequately explored e.g. adjacent to M4 Junction 17.

Criterion 4 re "alternatives to the private car". I fully support this concept but

(1) cycleways must include upgrading all parts of the routes to key facilities. Currently the narrow roads and volume of traffic make it extremely dangerous to cycle through central Chippenham - dedicated cycle lanes are needed.

(2) it must be recognised that many people cannot or do not want to cycle due to age, children, disability, bad weather, weight of shopping, need to shower and change clothes, etc

(3) many journeys are outside central Chippenham - to out of town supermarkets, sports facilities and commuting to work. All of these are much easier in a private car, so realistically cars will continue to be the transport of choice and must be planned for accordingly.

Criterion 5 re "acceptable landscape impact" and "biodiversity". These are really 2 separate criteria and should carry appropriate weighting. We have previously been assured that the area East of Chippenham within Bremhill Parish is a "valued Wiltshire landscape" and should be protected under Core Policy 51 with the equivalent of a "rural buffer zone”. This potential development site is on rising land which would be very visible and audible from the surrounding villages which are within the Bremhill parish. The detailed criteria around "biodiversity" was omitted from the draft Assessment Framework and yet this is critical.

Criterion 6 re "flood risk" - this is extremely important to communities living near the Rivers Avon and Marden as any additional flood water in Chippenham backs up the rivers causing damage to agricultural land and flooding of nearby roads which become impassable by the local communities. A Flood Risk Assessment of one in a thousand years should be a standard requirement for any development proposed adjacent to or in the proximity of any river.

Criterion 4 re

Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) Detailed comments on the proposed criteria in CP10 are noted. Many are at a level of detail appropriate to the Chippenham Site Allocations DPD and will be considered to help develop the Chippenham Site Assessment Framework referred to by the respondent. The criteria suggested within Core Policy 10 are intended to provide a systematic basis to both guide the allocation of sites and for the Officer Response determination of planning applications in the interim. At this stage there is no proposal for development on specific areas of land at Chippenham. It is the intention, through the Chippenham Site Allocations DPD to assess all strategic areas. The criteria proposed in CP10 will be used to guide this process and include criteria to ensure valued greenspace and areas liable to flood are protected

Consultee Agent Is the Change ms marilyn mackay legally No Comment 187 compliant? ID: Is the Change No Person ID: 780593 Person ID: sound? Positively prepared

Identified proposed Reasons for TPL/25 Justified change unsound

Effective TPL/25 is only a small part of the massive documentation with reference to the Chippenham Site Assessment Framework. Another document needed for comment is EXAM 78B (which includes 1.5 Chippenham Sites Allocations DPD); also, EXAM 99, 3.6 Core Policy 10 - Spatial Stregy: Chippenham community sites. There is simply TOO MUCH DOCUMENTATION on which to reasonably respond in this consultation, yet we DO NOT HAVE THE SITES ON WHICH TO FIRMLY COMMENT HERE. It is only a diagram, of sites A - E, of which i assume site C would encroach into ANOTHER COMMUNITY AREA, namely Calne. THIS WHOLE DISCUSSION SHOULD BE OPEN TO BROADER PUBLIC MEETINGS TO INCLUDE BOTH CHIPPENHAM AND CALNE RESIDENTS, who are stakeholders of this area. Only a brief, one-off so-called 'community meeting' has been held, to 'develop and inform' these site selection/criteria. THIS FAILS AS SUFFICIENT PUBLIC CONSULTATION and for this reason i am challenging its LEGAL compliance.

As to reasons it is not 'sound' and positively prepared, justified, effective, comments are below. Really there are insufficient words to say how much this process FAILS. the results are chaotic, and as a consequence it is not effective. It has not been 'justified' as to why and how a site is perhaps planned to go beyond both a Settlement boundary, and an Area boundary, and on which Policy this is Please give details of permitted. Planning to go beyond settlement boundaries are usually firmly restricted. In this case possible site C would encroach why you support or close to the boundary of a Conservation Village, Tytherton Lucas, which goes against planning values of 'conservation'. There is too do not support the much to say here, but below are some rssponses, but there is much more to say: consultation material. TPL/25 sets out, under Core Policy 10, six criteria for evaluating the revised site allocations for Chippenham. These 6 criteria are extremely high level and I have not seen the final Chippenham Site Assessment Framework which should provide more detail. From what has been provided so far several aspects are "unsound" as follows: Criterion 1 re "employment development" - this is absolutely critical if we are to avoid adding evermore commuters and consequent traffic to the population of Chippenham. However, employment isn't simply a matter of "delivery of premises". The potential for different sectors and their requirements e.g. transport, skilled workers, broadband , etc needs to be fully understood and provided, before approval is given for building homes. Criterion 2 re "delivery of facilities and infrastructure". Before approving any developments, Chippenham needs a detailed plan of the additional facilities and infrastructure required to support a much larger population. Some of these items will be very expensive and an appropriate CIL will need to be levied across all new developments to ensure sufficient funding is raised to put all of the necessary facilities and infrastructure in place. Criterion 3 re "traffic access" and "traffic impacts". Chippenham is already gridlocked in the rush hour. The A350 ring road needs to be duelled all the way around Chippenham. The A4 needs a Southern bypass to avoid the current jams around the south of the town centre. Any new housing developments should avoid contributing to the gridlock around the town centre and should have direct access to the primary route network. Careful consideration should be given before any further facilities are developed Powered by Objective Online 4.2 - page 7 in the centre of Chippenham e.g. new offices, additional shopping areas, etc as these will only exascerate the traffic problems. Alternative out of town sites should be adequately explored e.g. adjacent to M4 Junction 17. Criterion 4 re "alternatives to the private car". I fully support this concept but (1) cycleways must include upgrading all parts of the routes to key facilities. Currently the narrow roads and volume of traffic make it extremely dangerous to cycle through central Chippenham - dedicated cycle lanes are needed. (2) it must be recognised that many people cannot or do not want to cycle due to age, children, disability, bad weather, weight of shopping, need to shower and change clothes, etc (3) many journeys are outside central Chippenham - to out of town supermarkets, sports facilities and commuting to work. All of these are much easier in a private car, so realistically cars will continue to be the transport of choice and must be planned for accordingly. Criterion 5 re "acceptable landscape impact" and "biodiversity". These are really 2 separate criteria and should carry appropriate weighting.We have previously been assured that the area East of Chippenham within Bremhill Parish is a "valued Wiltshire landscape" and should be protected under Core Policy 51 with the equivalent of a "rural buffer zone?. This potential development site is on rising land which would be very visible and audible from the surrounding villages which are within the Bremhill parish. The detailed criteria around "biodiversity" was omitted from the draft Assessment Framework and yet this is critical. Criterion 6 re "flood risk" - this is extremely important to communities living near the Rivers Avon and Marden as any additional flood water in Chippenham backs up the rivers causing damage to agricultural land and flooding of nearby roads which become impassable by the local communities. A Flood Risk Assessment of one in a thousand years should be a standard requirement for any development proposed adjacent to or in the proximity of any river. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) Detailed comments on the proposed criteria in CP10 are noted. Many are at a level of detail appropriate to the Chippenham Site Allocations DPD and will be considered to help develop the Chippenham Site Assessment Framework referred to by the respondent. The criteria suggested within Core Policy 10 are intended to provide a systematic basis to both guide the allocation of sites and for the determination of planning applications in the interim. At this stage there is no proposal for development on specific areas of land at Chippenham. It is the intention, through the Chippenham Site Allocations DPD to assess all strategic areas. The criteria proposed in CP10 will be used to guide this process and include criteria to ensure valued greenspace and areas liable to flood are protected

Officer Response The Chippenham Site Allocations DPD will identify land for strategic sites and provide certainty and greater detail about the town's expansion. The local community will be fully involved in its preparation and this will take account of Neighbourhood Plans in production and ensure that there is collaboration and coordination between teams working on the plans to achieve consistency. In so doing a pattern of development can be produced which ensures the most valuable green space around Chippenham, such as the River Avon corridor, is protected while the economic potential of Chippenham is realised. The criteria suggested within Core Policy 10 are intended to provide a systematic basis to both guide the allocation of sites and for the determination of planning applications in the interim.

Consultee Agent Is the Change Miss Katie Sprackman legally Yes Comment 206 Hallam Land Management compliant? ID: Is the Change No Person ID: 840626 Person ID: sound? Positively prepared

Justified Identified proposed Reasons for TPL/25 change unsound Effective

Consistent with national policy Core Policy 10 still reads as though the figure is restricted. The current wording suggests that numbers could be increased at Chippenham but possibly at the expense of housing in the other parts of the Community Area. To correct this, CP10 should be amended by removing "approximately" in the first sentence and replacing it with "at least".

We do not agree that all sites need to be ‘mixed-use' as suggested in the amended Strategy for the Chippenham Community Area, as there can sometimes be a right place for employment and a right place for housing. It is however important that housing is located Please give details of close to employment opportunities; has good transport accessibility; and can access a range of community facilities. why you support or do not support the Whilst we encourage the strategy for ‘significant job growth' at Chippenham, there is not enough analysis and emphasis in the plan consultation material. regarding how the economy is linked to housing growth. We recognise the driving strategy of attempting to improve self-containment for Chippenham but the role of housing in economic growth should be explicitly stated.

CP10 also identifies criteria on which the DPD will be based. We do not think that there is a need to identify these criteria in the Core Strategy as that should be done within the DPD. If the criteria are to stay (as they are based on sound planning principles) then they need to be extended to explicitly include factors such as viability and deliverability (although they are hinted at in criteria 2). Does your representation relate to a previous one you submitted. If so, has the Council satisfied your I did not submit any comments on the objection through the proposed changes previous stage

Attached files (Please see Objective) Policy CP10 includes both indicative and minimum housing proposals for different parts of the community area, therefore together 'approximately' is used correctly in the policy wording.

The criteria suggested within Core Policy 10 are intended to provide a systematic basis to both guide the allocation of sites in the Officer Response Chippenham Site Allocations DPD and to help in the determination of planning applications in the interim. They reflect the key issues identified in the Chippenham area strategy and raised through consultation on the core strategy.

Deliverability of sites during the plan period will be a key test for any DPD (which is reflected in criteria 1 and 2 as recognised by the respondent). Deliverability and viability will form part of its examination to ensure the DPD is sound.

Consultee Agent Is the Change Mr Steven Perry legally Yes Comment 208 Chippenham Community Voice compliant? ID: Is the Change No Person ID: 840555 Person ID: sound? Positively prepared

Identified proposed Reasons for Appendix C, page 84 Justified change unsound

Effective Please give details of The map of Chippenham shown on page 84 is not fit for purpose. Areas A to E are indistinct and not clearly defined. This lack of why you support or definition adds to the already existing uncertainty resulting from the proposed MINIMUM ALLOCATION proposals. The map should be do not support the withdrawn, redefined so it is easily understood, and resubmitted as part of a revised TPL/10. consultation material. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) The purpose of the diagram is to indicate strategic areas within which the Council will consider the allocation of strategic mixed use Officer Response development sites through the preparation of separate Chippenham Site Allocations DPD. It is not intended to identify specific sites for development.

Consultee Agent Is the Change Mr Kim Stuckey legally Yes Comment 210 compliant? ID: Is the Change No Person ID: 375804 Person ID: sound? Positively prepared Identified proposed Reasons for change unsound Effective The development areas for Chippenham are shown in Appendix C of "Schedule of Proposed Modifications,incorporating EXAM 73 and EXAM 74" - a title of a document which in itself shows the complete democratic deficit for reviewing the Core Strategy as a member of Please give details of the public. why you support or do not support the Appendix C looks like it has been drawn by a 7 year old with some crayons. This is the most important (indeed only) visual image for consultation material. informing the people of Chippenham where development could possibly take place in their town, yet the process is so flawed that even a map cannot be produced of the development areas.

Attached files (Please see Objective) The purpose of the diagram is to indicate strategic areas within which the Council will consider the allocation of strategic mixed use Officer Response development sites through the preparation of a separate Chippenham Site Allocations DPD. It is not intended to identify specific sites for development.

Consultee Agent Is the Change Mr Kim Stuckey legally No Comment 216 compliant? ID: Is the Change No Person ID: 375804 Person ID: sound? Positively prepared

Identified proposed Reasons for Justified change unsound

Effective People of Calne Community Area, specifically Bremhill Parish, have not been made aware that a development site for Chippenham is included in the Core Strategy which is actually part of their parish. This is Site C in Appendix C of the Strategic Areas of Search for Please give details of Chippenham (although you are making an intepretation of a ridculous diagram rather than a map in coming to this conclusion). Any why you support or member of the public in Bremhill Parish or the wider Calne Communciy area would naturally review the Core Strategy for the impact on do not support the their Community Area, not look at developments for the Chippenham Community Area. So there has been no opportunity for the consultation material. people of Bremihill Parish to be informed that potentially massive development could take place in their parish and indeed not a single mention of this in the plan for their Community Area. This makes the Strategy and consultation process at a minimum unsound and probably not legally complient. Does your representation relate to a previous one you submitted. If so, has the Council satisfied your No, the Proposed Modification does not objection through the proposed changes meet a previous objection

Attached files (Please see Objective) The purpose of the diagram is to indicate strategic areas within which the Council will consider the allocation of strategic mixed use development sites through the preparation of a separate Chippenham Site Allocations DPD. It is not intended to identify specific sites for development. The strategic areas are based on known areas promoted by developers which have previously been publicised as part of the core strategy process. Officer Response The Chippenham Site Allocations Plan will be legally compliant, subject to consultation and independent examination. Indeed invitations to a recent event to discuss the evolving Chipenham Site Allocations DPD was advertised recently through the Calne Area Board to ensure the Calne community area are aware of the fledgling plan.

Consultee Agent Is the Change Mr Richard Hames legally Comment 240 compliant? ID: Is the Change

Person ID: 394998 Person ID: sound? Identified proposed Reasons for TPL/25 change unsound Decisions on where the sites should be allocated should be made on social, economic and environmental factors that make up sustainable development as set out in the National Planning Policy Framework.

1. The scope f or the area to ensure the delivery of premises and land for employment development reflecting the priority to support local economic growth and settlement resilience

The Core Policy is seeking to retain jobs in the County. Chippenham has a very high level of out - commuting so employment land should be such as Langley Park. Development to the east of Chippenham will result in an encroachment of Tytherton Lucas affecting settlement resilience.

2. The capacity to provide a mix of house types, for both market and affordable housing alongside the timely delivery of the facilities and infrastructure necessary to serve them

The costs of the infrastructure for the east of Chippenham are very heavy - can the developer deliver? Please give details of why you support or 1. Eastern link road cost: it will be very expensive to build due to its length; as Chippenham 2020 does not own all the land on do not support the which the road will be built it will be necessary for them to pay a ransom to owners to the north of their site; to Barratts at consultation material. Rawlings Green; and to the Council towards Abbeyfields. In addition they will need to cross the railway line which will result in a further ransom payment. Finally they will need to build a bridge over the River Avon - see below. 2. Eastern link road deliverability : the cost of paying ransoms to landowners and Network Rail and of building the bridge over the rail line and the River Avon will be very expensive. Can they deliver? 3. Eastern link road river crossing : How will they cross the Avon? Will it be a free span bridge? This will be very expensive and will further impact whether they can deliver. Will they seek to reduce s106 payments and will they seek to reduce affordable housing? Wiltshire desperately needs affordable housing so costs of infrastructure are hugely important as they affect viability. This is an argument used by developers to reduce the percentage of affordable housing on their sites. An alternative bridge design may be cheaper but would need to be supported in the floodplain and therefore has greater flood risk affect. Will this type of bridge be acceptable to the Environment Agency? 4. At the Core Strategy Examination last year it was stated by Chippenham 2020 that 400 houses could be built to the East of Chippenham before the link road is built. Can the centre of Chippenham cope with such additional traffic? If 400 houses are built there is the danger that the link road ends at this point and never gets built. Will they deliver the link road ever? Should it not be built first?

3. Improves local traffic access to the primary road network and redresses traffic impacts affecting the attractiveness of the town centre

How can development not result in increasing bottlenecks at critical junctions eg around the Bridge Centre.

A new traffic scheme is required for Chippenham before any planning consent is given.

The primary roads around Chippenham are the A350 and M4, thus the A350 should be made a dual carriageway as the bridges over the A350 were built with that in mind and land has been reserved for this. In the longer term a southern link road could link the A4 to the A350.

In defining the Town centre, it is critical that the town centre is the town centre - ie where the shops and most economic activity occurs. This should be defined in this point 3 and sensibly it would be where the Town Hall is in the High Street. Anywhere else eg Monkton Park would be unsound.

4. Improves accessibility by alternatives to the private car to the town centre, railway station, schools and colleges

See above for paragraph on Town Centre location.

Much is made of alternative methods of transport to the town centre "particularly bicycle". Whilst this is an excellent aspiration we are still awaiting the Chippenham Transport Strategy. This aspiration will need detailed input to show where cycleways can be provided and pedestrian and cyclelinks provided to link different part of the town . Many are unable to cycle due to weather/age/ disability/carrying shopping etc.

5 Has an acceptable landscape impact upon the countryside and the settings to Chippenham and surrounding settlements, improves biodiversity and access to the countryside

This criteria should be expanded to include ENJOYMENT (eg environmental quality of the open spaces around Chippenham and the surrounding villages). Access could be improved but enjoyment ruined by traffic and buildings.

It should also specifically refer to "enhancing Wiltshire's distinctive landscape character".

For example , The Wilts & Berks Canal Trust aims to recreate the canal include leisure use, a wildlife corridor and restoring/preserving history.Their priorities are:

1. firstly to restore the towpath (target 5 years) for walking, cycling and possibly horse riding, then 2. rebuild the canal - extending northeastwards from the Kennet & Avon canal at Semington.

They are obtaining planning permission for a revised route around Melksham and then via the River Avon to join up with the partially restored Pewsham section. Potentially the next section to restore would be between Pewsham and Foxham and finally to rebuild the links to Chippenham and possibly Calne.

The original route into Chippenham has been built over but there is an outline alternative route following the old railway track westwards and joining the River Avon between Hardens Farm and NewLeaze Farm.

6. Avoids all areas of flood risk (therefore within zone 1) and surface water management reduces the risk of flooding elsewhere

"Reduces the risk of flooding elsewhere" is not clear; it is too vague. Does it mean the developer will take steps to reduce the run off caused by the development OR does it mean the developer will ensure regardless of heavy rain NO extra run off will enter the rivers Avon and Marden which affect Chippenham , or other areas of flood risk in and around the town?

This is important if we are to make sure that the villages in Bremhill Parish are not adversely affected and flooding increased with all the problems that go with it.

A Flood risk Assessment of one in a thousand years should be a standard requirement for any development proposed adjacent to or in the proximity of any river.

New criteria 7. This should be added as an additional criteria by which to judge the suitability of any development.

Conclusion: Thank you for reading this. If you have any questions please let me know Does your representation relate to a previous one you submitted. If so, has the Council satisfied your objection through the proposed changes

The Chippenham Site Allocations DPD will identify land for strategic sites and provide certainty and greater detail about the town's expansion. The local community will be fully involved in its preparation and this will take account of Neighbourhood Plans in production Officer Response and ensure that there is collaboration and coordination between teams working on the plans to achieve consistency. In so doing a pattern of development can be produced which ensures the most valuable green space around Chippenham, such as the River Avon corridor, is protected while the economic potential of Chippenham is realised. Criterion 5 would benefit from explicit reference to the 'enjoyment' the countryside not just access and this should be added to the suggested wording. The criteria suggested within Core Policy 10 are intended to provide a systematic basis to both guide the allocation of sites and for the determination of planning applications in the interim.

The Chippenham Site Allocations DPD will be subject to Sustainability Appraisal to inform the process of site selection and policy development.

Consultee Agent Is the Change Mrs Sandra Hames legally Comment 265 compliant? ID: Is the Change

Person ID: 840685 Person ID: sound? Identified proposed Reasons for TPL/25 change unsound Decisions on where the sites should be allocated should be made on social, economic and environmental factors that make up sustainable development as set out in the National Planning Policy Framework.