Crudwell Neighbourhood Plan Decision Statement (Proceeding to Referendum)

CRUDWELL NEIGHBOURHOOD PLAN DECISION STATEMENT (PROCEEDING TO REFERENDUM)

1. INTRODUCTION

1.1. Pursuant to the Wiltshire Council constitution and in particular Part 3D, the Interim Corporate Director for Place and Environment within whose remit Spatial Planning falls is authorised to make decisions on Neighbourhood Plan proposals following the examination of a Neighbourhood Plan proposal in accordance with the Town and Country Planning Act 1990 (as amended) and the Neighbourhood Planning (General) Regulations 2012 (as amended) and all other relevant legislation.

2. BACKGROUND

2.1. The designated area for the Crudwell Neighbourhood Plan comprises the whole of the parish of Crudwell. On 20th March 2015 Wiltshire Council formally approved that the Crudwell Neighbourhood Area (i.e. the land within the parish of Crudwell) be designated in accordance with the Neighbourhood Planning (General) Regulations 2012.

2.2. Crudwell Parish Council – the ‘qualifying body’, submitted the draft Crudwell Neighbourhood Plan 2019-2026 (submission version May 2020), along with supporting documents, to Wiltshire Council on 12th May 2020 for consultation, independent examination and the remaining stages of the draft Plan’s preparation in accordance with the Neighbourhood Planning (General) Regulations 2012.

2.3. Following submission of the draft Crudwell Neighbourhood Plan, Wiltshire Council publicised the Plan and supporting documents and invited representations during the consultation period 29th June 2020 to 24th August 2020.

2.4. In October 2020, Wiltshire Council appointed an independent examiner, Mr Nigel McGurk BSC (Hons) MBA MCD MRTPI, to examine the draft Plan and consider whether it should proceed to referendum.

2.5. The examiner’s report was received in December 2020 and concluded that subject to making the modifications recommended in the report, that the draft Plan meets the Basic Conditions and should proceed to referendum. The examiner also recommended that the Crudwell Neighbourhood Area (the parish area) is an appropriate area within which to hold a referendum.

2.6. In accordance with legislation, Wiltshire Council must consider each of the recommendations made in the examiner’s report, decide what action to take in response to each recommendation and what modifications should be made to the draft

Plan in order to be satisfied that it meets the Basic Conditions and is compatible with Convention Rights. If the authority is satisfied, then a referendum must be held. Consideration also needs to be given as to whether to extend the area to which the referendum is to take place.

3. DECISION AND REASONS

3.1. Wiltshire Council must be satisfied that the neighbourhood plan meets the Basic Conditions, is compatible with the Convention rights and complies with the provision made by or under sections 61E (2), 61J and 61L of the Town and Country Planning Act 1990, or that the draft order would meet those conditions, be compatible with those rights and comply with that provision if modifications were made to the draft order.

3.2. Wiltshire Council has considered the examiner’s recommendations and reasons for them. Wiltshire Council has decided to make the examiner’s modifications with additional modifications by the Council to the draft Crudwell Neighbourhood Plan, for the purpose of correcting errors (which includes amendments necessary to achieve accuracy and consistency in the wording of policies and supporting text) and to ensure that it meets legal requirements, including the Basic Conditions as set out in legislation. Appendix 1 sets out these modifications, together with the reasons for them.

3.3. The Council is satisfied that the Neighbourhood Plan, as modified, complies with the legal requirements and can proceed to referendum.

3.4. The Council also agrees with the examiner that the referendum area should reflect the extent of the parish of Crudwell.

3.5. I declare that I have no private interest in respect of this matter that would prevent me from making this decision.

Signed:

Sam Fox

Sam Fox Interim Corporate Director for Place and Environment Wiltshire Council

Dated: 23rd December 2020 APPENDIX 1

Modifications required to be made to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) in response to the Examiner’s recommendations and to correct errors

Guidance for using this document

The following table sets out the modifications that are required to be made to the Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) together with the explanation and reason for the modification. This should be read alongside the report dated December 2020 of the independent examiner, Nigel McGurk to Wiltshire Council on the draft Crudwell Neighbourhood Plan.

Throughout the table, specific changes that are required are shown as follows:

• text in bold and underlined identifies new text to be added to the Plan.

• text that is shown as red italic strikethrough identifies text to be deleted from the Plan.

The relevant paragraph, policy and page numbering relates to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020), hereafter referred to as the ‘CNP’, as submitted to Wiltshire Council. For each change, the table sets out the examiner’s recommendation as set out in his report together with the modification that is required to be made to the neighbourhood plan. Some additional changes are also included that are not in the examiner’s report to correct errors such as typos.

As a result of some modifications, consequential amendments may be required to the final CNP to be published for the purposes of the referendum. These can include changing section headings, amending the contents page, renumbering paragraphs or pages and ensuring that supporting appendices and other documents align with the final version of the Plan.

1 APPENDIX 1

REQUIRED MODIFICATION:

• Replace the plan on page 8 with a plan that clearly identifies the boundary of the Crudwell Neighbourhood Area.

R2 Page 18 Page 7, EXAMINER COMMENT: In the interest of clarity. end of Paragraph 2.6 of the Neighbourhood Plan appears as an isolated paragraph 2.6, statement. For clarity after the bullet points add “The objectives of the after bullet Neighbourhood Plan, as set out in Section 7, have emerged from these points four topic areas.”

REQUIRED MODIFICATION:

• Amend Page 7, end of paragraph 2.6, add (after the bullet points) as follows:

“Following the initial engagement undertaken in late 2017, the responses were compiled, and the responses grouped by topic. This grouping led to four focus groups being set up to deal with the following four topics:

● Development and Design; ● Infrastructure and Transport; ● Environment; and ● Community and Leisure.

The objectives of the Neighbourhood Plan, as set out in Section 7, have emerged from these four topic areas.”

2 APPENDIX 1

REQUIRED MODIFICATION:

• Delete paragraph 3.19 as follows:

“A draft Neighbourhood Plan has some limited weight in the way planning applications in Crudwell are determined, and this weight increases as it gets closer to the end of the process, when it is made.”

R4 Page 18 Page 16 EXAMINER COMMENT: In the interest of clarity. Paragraph 5.2 A Consultation Statement was submitted alongside the Neighbourhood Plan in accordance with the Regulations. Section 5 of the Neighbourhood Plan briefly refers to the Consultation Statement and for clarity I recommend modifying paragraph 5.2.

REQUIRED MODIFICATION:

• Modify paragraph 5.2 as follows:

The community engagement undertaken to date is summarised in the Consultation Statement was detailed in the Consultation Statement produced and submitted in support of the Neighbourhood Plan.

R5 Page 18 Section 6 EXAMINER COMMENT: In the interest of clarity and typo Subsection 6.1 error. Lines 7, 11, 15 Section 6 presents the vision for the Neighbourhood Plan. Whilst this is & 16 generally clear, the use of the word “ensures” results in a vision that appears to go beyond the ability of plan-makers to control.

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• Modify line 7, line 11, line 16 and delete inverted commas at end of line 15 of subsection 6.1 as follows:

“In 2026, the Parish of Crudwell will remain a vibrant, inclusive, rural community, which is home to residents of all generations.

The parish will have sought to ensure the that facilities and infrastructure needed are in place to enable the community to remain vibrant and inclusive, and that the school, church, local businesses, village hall and recreation facilities will have been protected and enhanced where possible.

Any nNew residential development will meet have sought to meet the needs of those within the Parish, with a focus on enabling young adults to remain. Any development will have taken into account the views of the local community, and will be sensitively designed to reflect the attractive rural location and to protect the conservation area.”

The parish will have sought to improve Ppublic transport connections to Malmesbury and Kemble station will have been improved, as well as will the safety of road users around the parish.”

R6 Pages 19 Section 7 EXAMINER COMMENT: In the interest of clarity.

Similar to R5 above, two of the Objectives in Section 7 run the risk of going beyond the abilities of the Neighbourhood Plan in respect of delivery.

REQUIRED MODIFICATION:

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Development and Design ● To deliver new housing that meets local needs and is community led. ● To seek to ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately.

Infrastructure and Transport ● To deal with flooding and sewage issues, and seeking the upgrade of the systems in order to meet the current and future needs of our community. ● To seek to ensure a free and safe flow of traffic in our community, with any new development contributing towards this objective, and to ensure minimum impact on existing roads system, especially at junctions and in relation to the issue of parking around the primary school. ● To seek to ensure that any development helps to encourage sustainable forms of transport and specifically includes adequate and safe routes for walking, cycling and horse riding. ● To nurture and protect Crudwell School. ● To seek faster broadband speeds and better mobile phone coverage in the Parish, especially in the outlying areas and smaller villages. ● To seek to improve local bus services, adopting a more integrated approach to links with Malmesbury, Cirencester and Kemble railway station and with connecting services, to improve commuter connections and local journeys in line with the needs of the community.

5 APPENDIX 1

Modifications required to be made to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) in response to the Examiner’s recommendations and to correct errors Reference Page in Related CNP Recommendation and proposed modification Reason for modification number Examiner’s page / section Report R7 Page 19 Page 28, Policy EXAMINER COMMENT: For the avoidance of doubt and DD1 to ensure clarity of the Policy. Page 31, Policy Policy DD1 establishes a number of “Requirements.” These DD2 “Requirements” have no Policy status but, whilst they are intended to Page 34, Policy provide detail relating directly to Policy DD1, they appear as Policy IT1 requirements. In effect, as presented, the Neighbourhood Plan seeks to Page 37, Policy establish Policy requirements outside of the relevant Policy and does so IT2 even before the relevant Policy has been set out. Page 39, Policy CL1 Consequently, it is not clear how such “Requirements” should be treated by a decision maker. This detracts significantly from the clarity of the Neighbourhood Plan and presents a confusing approach, contrary to Paragraph 16 of the Framework, which states that plans should: “…contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.”

REQUIRED MODIFICATION:

• Present each of the following Policy after the general introductory text but before corresponding explanatory information, as follows:

Policy DD1 to appear after para 9.10

Policy DD2 to appear after para 9.55

Policy IT1 to appear after para 10.13

Policy IT2 to appear after (bullet points in) para 10.22

Policy CL1 to appear after para 11.8

6 APPENDIX 1

REQUIRED MODIFICATION:

• Provide a new plan of the Tuners Lane site, clearly identifying the site boundaries against a clear Ordnance Survey (or equivalent) base and insert the said plan below Policy DD1.

R9 Pages 20 - Page 28 EXAMINER COMMENT: In the interest of accuracy and 25 Policy DD1 clarity. Change the opening paragraph of Policy DD1 to “…identified on the plan below and on the policies map...dwellings, 40% of which will be affordable. Development of the Tuners Lane site should:”

REQUIRED MODIFICATION:

• Modify the opening paragraph of Policy DD1 as follows:

“A site of 1.3 hectares identified on the plan below and the policies map is allocated for a residential development of 20 to 25 dwellings, 40% of which will be affordable. Development of the Tuners Lane site should:

Development proposals must: “

7 APPENDIX 1

REQUIRED MODIFICATION:

• Amend criterion a) within Policy DD1 as follows:

“a) Improve foot/ cycle access to the primary school and other village facilities including bus stops. and to bus stops for secondary school pupils and others. In particular, complete the footway along Tuners Lane from the allocated housing site to the A429 whilst retaining existing on- street parking; “

R11 Page 23 , Page 28 EXAMINER COMMENT: For the avoidance of doubt and paragraph Policy DD1, in the interest of clarity. 103 and criterion b) Wiltshire Council has proposed an addition to the second criterion of page 26 Policy DD1 in respect of seeking to ensure that native hedgerow trees are included where hedgerows are replanted.

REQUIRED MODIFICATION:

• Modify the last sentence of criterion b) of Policy DD1 as follows:

“b) Protect the natural environment, encourage biodiversity and protect green spaces and the rural feel of Crudwell. In particular, demonstrate as much of the hedgerow fronting Tuners Lane is retained as is practicable, in relation to both the location of the access and visibility splays. Where any hedgerow is lost as a result of visibility splays, it must be reprovided immediately outside the splay replanted immediately outside the splay and incorporate occasional native hedgerow trees; “

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There is no statutory requirement for all development to enhance the setting of a Conservation Area nor, in any case, is there any substantive evidence to demonstrate that any such a requirement would, in this instance, be deliverable.

Heritage policy is generally concerned with “conserving” rather than “protecting” and further, it is not apparent why it is relevant for development at Tuners Lane to conserve heritage assets, given there is no evidence that any such assets are present within the site. Change criterion c) to “Conserve the setting of any heritage assets upon which the development of Tuners Lane may have an effect, including Crudwell Conservation Area;”

REQUIRED MODIFICATION:

• Modify criterion c) of Policy DD1 as follows:

“c) Protect and enhance heritage assets and their settings through appropriate mitigation measures Conserve the setting of any heritage assets upon which the development of Tuners Lane may have an effect, including Crudwell Conservation Area;“

R13 Page 24, Page 29 EXAMINER COMMENT: In the interest of clarity and in paragraphs Policy DD1, compliance with the basic 108 & 109 criterion e) Change criterion e) to “…play area on site;” (delete rest of conditions. and page 26 sentence)

In this regard, I also note Wiltshire Council’s comment that there is no

9 APPENDIX 1

REQUIRED MODIFICATION:

• Modify criterion e) of Policy DD1 as follows:

“e) Provide an equipped children’s play area on site and provide funding towards a more substantial play facility for older children/teenagers at the village hall site; “

R14 Page 23, Page 29 EXAMINER COMMENT: In the interest of clarity and Paragraph Policy DD1, regard to national policy. 100 and criterion f) Whilst Policy DD1 is ambiguous in this regard, the supporting information page 26 suggests that the housing mix at Tuners Lane should reflect local housing needs and that the sizes and types of housing will emerge from “discussion between the developer and the Community Liaison Group.” Policy DD1 should therefore provide for this, having regard to national policy. Change criterion f) to “The mix of housing types and sizes should meet identified local needs.”

REQUIRED MODIFICATION:

• Modify criterion f) of Policy DD1 as follows:

“f) In addition to providing 40% affordable housing as required by the Wiltshire Core Strategy, the remaining market housing should predominantly be smaller, low cost dwellings The mix of housing types and sizes should meet identified local needs; “

10 APPENDIX 1

Modifications required to be made to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) in response to the Examiner’s recommendations and to correct errors Reference Page in Related CNP Recommendation and proposed modification Reason for modification number Examiner’s page / section Report R15 Page 24, Page 29 EXAMINER COMMENT: In the interest of accuracy and paragraph Policy DD1, clarity. 110 and criterion g) Whilst it is recognised that it is essential to ensure that development does page 26 not increase flood risk either at the Tuners Lane site or elsewhere, the wording of this part of Policy DD1 sets out requirements not supported by substantive deliverability evidence and I recommend the replacement of this part of the Policy with the clear and unambiguous wording proposed by Wiltshire Council. Replace criterion g) with “Ensure that the site does not flood from any source of flooding and that the surface water drainage scheme provides betterment over existing runoff rates and volumes, without increasing flood risk elsewhere. Incorporate sustainable drainage systems that provide multifunctional benefits (water quantity, water quality, amenity and biodiversity);”

REQUIRED MODIFICATION:

• Modify criterion g) of Policy DD1 as follows:

“g) Ensure that the site does not flood and that it will drain safely and a lower rate than currently, even in periods of high rainfall, without exacerbating, and ideally ameliorating, flooding elsewhere Ensure that the site does not flood from any source of flooding and that the surface water drainage scheme provides betterment over existing runoff rates and volumes, without increasing flood risk elsewhere. Incorporate sustainable drainage systems that provide multifunctional benefits (water quantity, water quality, amenity and biodiversity); “

R15 Pages 25, Page 29, EXAMINER COMMENT: In the interest of clarity. paragraph Policy DD1, 111 and 26 criterion h) The Crudwell Design Guide provides a useful tool to help understand local character. However, it does not comprise adopted planning policy. It provides guidance rather than Policy requirements that development is

11 APPENDIX 1

REQUIRED MODIFICATION:

• Modify criterion h) of Policy DD1 as follows:

“h) Ensure that the design is in keeping with Crudwell’s character, having regard to and be demonstrated to be in accordance with the Crudwell Design Guide; “ R16 Page 25, Page 29, EXAMINER COMMENT: In the interest of clarity and the paragraph Policy DD1, NPPF. 112 and criterion i) The provision of fibre-optic superfast broadband is in general conformity page 26 with Wiltshire Core Strategy Core Policy 3 (“Infrastructure Requirements”). However, in the absence of detailed information, it is not clear why Policy DD1 seeks to restrict any provision to compliance with “section 7 of PAS2016:2010.” Communications technology does not stand still and as set out, the Policy does not have regard to Chapter 10 of the Framework, “Supporting high quality communications,” which requires plans to provide for digital infrastructure to be upgraded over time. Delete second sentence of criterion i) (“Internal…PAS2016:2010”)

REQUIRED MODIFICATION:

• Delete second sentence of criterion i) of Policy DD1 as follows:

“i) Provide broadband fibre to the premises (FTTP) to each dwelling on the allocation site, including ducting, cabinets and cabling, and improvements to local infrastructure where necessary. Internal digital infrastructure within new homes should comply with section 7 of PAS2016:2010; “

12 APPENDIX 1

REQUIRED MODIFICATION:

• Modify criterion j) of Policy DD1 as follows:

“j) Incorporate green/sustainable technologies into the design of the development and of individual dwellings., including This could include rainwater harvesting, grey water recycling, solar water heating, pV panels, electric car charging and/or high U-value insulation;”

R18 Pages 25, Page 29 EXAMINER COMMENT: In the interest of clarity and in paragraph Policy DD1, regard of national policy. 114 and criterion k) Education contributions are a matter between the Education page 26 Authority and the developer. Notwithstanding that the vague reference to this in Policy DD1 does not have regard to the national policy test for planning obligations, this is not a matter for determination by the Parish Council through the Neighbourhood Plan. Delete criterion k)

REQUIRED MODIFICATION:

• Delete criterion k) of Policy DD1 as follows:

k) Provide funding towards primary school improvements to cater for the additional primary school children that would result from the development.

13 APPENDIX 1

Modifications required to be made to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) in response to the Examiner’s recommendations and to correct errors Reference Page in Related CNP Recommendation and proposed modification Reason for modification number Examiner’s page / section Report R19 Pages 25, Page 29 EXAMINER COMMENT: In the interest of clarity and in paragraph Policy DD1 compliance with the basic 115 and Following on from consultation related to the HRA screening process, it conditions. page 26 was determined that any planning application for development at the Tuners Lane site must be subject to an Appropriate Assessment and that mitigation would be required and must be agreed before the application is submitted. Add new paragraph to Policy DD1 below the bullet points: “Any planning application for development at the allocated site will be subject to an Appropriate Assessment. Mitigation will be required and must be agreed before the application is submitted. This will likely comprise either a stand-alone mitigation scheme or contribution to such a scheme, or contribution to a strategic scheme, and the advice of Natural England should be sought and taken into consideration as part of the process.”

REQUIRED MODIFICATION:

• Add new paragraph to Policy DD1 below the bullet points as follows:

Any planning application for development at the allocated site will be subject to an Appropriate Assessment. Mitigation will be required and must be agreed before the application is submitted. This will likely comprise either a stand-alone mitigation scheme or contribution to such a scheme, or contribution to a strategic scheme, and the advice of Natural England should be sought and taken into consideration as part of the process.

R20 Page 22, Page 29, EXAMINER COMMENT: In the interest of clarity and in paragraph Policy DD1, last compliance with the NPPF. 92 and page paragraph The developer of the Tuners Lane site has committed to work together 27 with the community and this has regard to the National Planning Policy Framework, which recognises collaborative working between developers and the community as good practice that should be encouraged.

14 APPENDIX 1

REQUIRED MODIFICATION:

• Delete final paragraph of Policy DD1 and replace as follows:

“In delivering a residential development at Tuners Lane, the developer must work with a Community Liaison Group to produce a full planning application and to deal with the discharge of conditions. Matters for collaborative working between the developer and Parish Council/ nominees group will include those set out in criteria a) to k), along with site layout, dwelling design, dwelling mix (affordable and market homes), landscaping and public open space provision (type and location) Further details in respect of the requirements of this Policy are set out below. The Parish Council will seek to work closely with the developer in respect of the successful implementation of this Policy through the creation of a Community Liaison Group. Collaborative working with the community will be strongly supported.”

R21 Page 27 Page 22, EXAMINER COMMENT: In the interest of clarity and in paragraph 9.12 compliance with the NPPF. The developer of the Tuners Lane site has committed to work together with the community and this has regard to the National Planning Policy Framework, which recognises collaborative working between developers and the community as good practice that should be encouraged. However, whilst Wiltshire Council supports Policy DD1’s “requirement”

15 APPENDIX 1

REQUIRED MODIFICATION:

• Delete Para 9.12.

The nine requirements in the list below were drafted and discussed with developers to ensure that development would be viable and deliverable if these requirements were included in policy DD1. The developers confirmed that this would be the case. These requirements have become the criteria in policy DD1 below.

R22 Page 22, Page 22, EXAMINER COMMENT: In the interest of clarity and in paragraph paragraph 9.13 compliance with the NPPF. 92 and page The developer of the Tuners Lane site has committed to work together 27 with the community and this has regard to the Framework, which recognises collaborative working between developers and the community as good practice that should be encouraged. However, whilst Wiltshire Council supports Policy DD1’s “requirement” for the developer to work with the community, there is no basis for any such a requirement to form part of a statutory land use planning policy in this case.

REQUIRED MODIFICATION:

• Modify Para 9.13 as follows:

In order to ensure that the Tuners Lane development meets the community’s expectations, policy DD1 requires the site’s developer to work with the local community in preparing a full application for submission to Wiltshire Council for approval, and then in discharging conditions later. The local community would be represented by a Community Liaison Group nominated by Crudwell Parish Council. The

16 APPENDIX 1

R23 Page 22, Page 22, EXAMINER COMMENT: In the interest of accuracy and paragraph paragraph 9.16 clarity.. 92 and page The presentation of supporting text including “Requirements” ahead of 27 Policy DD1 is confusing and inappropriate. Whilst the use of the word “Requirements” outside of the Policy is inappropriate, the text contained in the supporting text provides important detailed information relating to the criteria set out in Policy DD1. Delete Para 9.16 and replace with “The following information provides further details in respect of the requirements of Policy DD1.”

REQUIRED MODIFICATION:

• Delete Para 9.16 and replace as follows:

“The relationship between the nine requirements and the neighbourhood plan objectives is set out below, and the justification for these is set out in more detail in the Sustainability Appraisal and Evidence Base The following information provides further details in respect of the requirements of Policy DD1. “

R24 Pages 22, Pages 22 to 28 EXAMINER COMMENT: In the interest of clarity. paragraph 94 and page There is no evidence to demonstrate that all of the requirements listed 27 are deliverable and I note that some of the requirements are, for example, vague or unclear.

17 APPENDIX 1

• Delete “Requirement (number)” at the start of each paragraph in bold. The paragraphs in bold should simply repeat the relevant criterion AS REVISED IN THE RECOMMENDATIONS ABOVE in Policy DD1 and not be headed as “Requirements.”

R25 Page 22, Page 22 EXAMINER COMMENT: In the interest of clarity. paragraph Paragraph 9.17 94 and page There is no evidence to demonstrate that all of the requirements listed 27 are deliverable and I note that some of the requirements are, for example, vague or unclear. In paragraph 9.17 delete “requirement” and change first and third bullet points to “To seek to ensure…”

REQUIRED MODIFICATION:

• In paragraph 9.17 delete “requirement” and change first and third bullet points as follows:

“This requirement responds to the following neighbourhood plan objectives:

• To seek to ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately. • To seek to ensure a free and safe flow of traffic in our community, with any new development contributing towards this objective, and to ensure minimum impact on existing roads system, especially at junctions and in relation to the issue of parking around the primary school. • To seek to ensure any development helps to encourage sustainable forms of transport and specifically includes adequate and safe routes for walking, cycling and horse riding. “

18 APPENDIX 1

REQUIRED MODIFICATION:

• Modify paragraph 9.18 as follows:

“Photos of the existing Tuners Lane roadway and footway are included below, and in relation to the Tuners Lane site, the implementation of requirement 1 means delivering Policy DD1 will require the delivery of the footway the footway improvements described, and shown to be deliverable, in paragraphs 2.1 to 2.4 and drawings 6807/201 and 6807/202 of the Site Access & Connectivity Appraisal at Appendix 16 of the Sustainability Appraisal and Evidence Base. This is included in policy DD1 as criterion a). “

R27 Page 22, Page 23, EXAMINER COMMENT: In the interest of clarity. paragraph paragraph 9.21 94 and page There is no evidence to demonstrate that all of the requirements listed 27 are deliverable and I note that some of the requirements are, for example, vague or unclear. At paragraph 9.21 delete “requirement”

REQUIRED MODIFICATION:

• At paragraph 9.21 delete “requirement” as follows:

“This requirement responds to the following neighbourhood plan objectives:

19 APPENDIX 1

R28 Page 22, Page 24 EXAMINER COMMENT: In the interest of clarity. paragraph Paragraph 9.26 94 and page There is no evidence to demonstrate that all of the requirements listed 27 are deliverable and I note that some of the requirements are, for example, vague or unclear, such as “and to bus stops for secondary school pupils and others;” and “appropriate mitigation measures.” At paragraph 9.26 delete “requirement,” change first bullet point to “To seek to ensure…” and delete “, especially for teenagers” from third bullet point

REQUIRED MODIFICATION:

• Delete at paragraph 9.26 “requirement,” change first bullet point to “To seek to ensure…” and delete “, especially for teenagers” from third bullet point.

“This requirement responds to the following neighbourhood plan objectives:

• To seek to ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately. • To maintain, protect and enhance existing community facilities, especially school, church, local businesses, village hall and open spaces. • To improve recreation facilities and opportunities, especially for teenagers. “

20 APPENDIX 1

“…plans to set out the contributions expected from development, where these are required.” (Paragraph 34, the Framework)

In this regard, I also note Wiltshire Council’s comment that there is no evidence in respect of the need for the facility. However, taking the supporting information submitted alongside the Neighbourhood Plan into account, I make a recommendation below to ensure that reference to the provision of facilities for local teenagers is not lost. At paragraph 9.29 change to “…on site. The Parish Council and local community is also concerned that there are insufficient play facilities for local teenagers. The Parish Council will seek to work with the developer to see if any such facilities can be provided, to the benefit of the local community, through the delivery of the development. The precise…”

REQUIRED MODIFICATION:

• Modify paragraph 9.29 as follows:

“Policy DD1 criterion e) seeks the provision of a play facility for younger children on site and funding towards improved play for teenagers at the village hall site. The Parish Council and local community is also concerned that there are insufficient play facilities for local teenagers. The Parish Council will seek to work with the developer to see if any such facilities can be provided, to the benefit of the local community, through the delivery of the development. The

21 APPENDIX 1

R30 Page 22, Page 25, EXAMINER COMMENT: In the interest of clarity. paragraph paragraph 9,30 94 and page There is no evidence to demonstrate that all of the requirements listed 28 are deliverable and I note that some of the requirements are, for example, vague or unclear. At paragraph 9.30 delete “requirement”

REQUIRED MODIFICATION:

• At paragraph 9.30 delete “requirement” as follows:

“This requirement responds to the following neighbourhood plan objectives:

• To deliver new housing that meets local needs and is community led. “

R31 Page 28 Page 25 EXAMINER COMMENT: In the interest of clarity. Paragraph 9.31 At paragraph 9.31, delete the last sentence (“This…f)).”

REQUIRED MODIFICATION:

• At paragraph 9.31, delete the last sentence as follows:

“In order to meet the community’s aspirations for new housing, and particularly to ensure that the Tuners Lane site provides the opportunity for local young adults and local people in less well paid jobs to remain in the parish, it is important that the housing providing on site delivers affordable housing and smaller, lower cost market housing. This is required by criterion f).”

22 APPENDIX 1

REQUIRED MODIFICATION:

• At paragraph 9.33 delete “requirement” and change first bullet point as follows:

“This requirement responds to the following neighbourhood plan objectives:

• To seek to ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately. • To deal with flooding and sewage issues, and seeking the upgrade of the systems in order to meet the current and future needs of our community. “

R33 Page 22, Page 25 EXAMINER COMMENT: In the interests of clarify. paragraph Paragraph 9.35 92 and page The developer of the Tuners Lane site has committed to work together 28 with the community and this has regard to the Framework, which recognises collaborative working between developers and the community as good practice that should be encouraged. However, whilst Wiltshire Council supports Policy DD1’s “requirement” for the developer to work with the community, there is no basis for any such a requirement to form part of a statutory land use planning policy in this case. Delete paragraph 9.35.

23 APPENDIX 1

• Delete paragraph 9.35.

Policy DD1 criterion g) requires the Tuners Lane site developer to demonstrate to the local community that this is the case via the Community Liaison Group before a planning application is submitted.

R34 Page 22, Page 26, EXAMINER COMMENT: In the interest of clarity. paragraph paragraph 9.37 94 and page There is no evidence to demonstrate that all of the requirements listed 28 are deliverable and I note that some of the requirements are, for example, vague or unclear. At paragraph 9.37 delete “requirement”

REQUIRED MODIFICATION:

• At paragraph 9.37 delete “requirement” as follows:

“This requirement responds to the following neighbourhood plan objectives:

• To protect and enhance our natural, built and historic environment, as a rural and agricultural community on the edge of the Cotswolds, by ensuring any new development is appropriately located and of a scale and design sympathetic to its surroundings. • To protect our Conservation area. “

R35 Pages 22 to Page 26, EXAMINER COMMENT: In the interests of clarity 25 and page paragraphs 28 9.38 and 9.39 The developer of the Tuners Lane site has committed to work together with the community and this has regard to the Framework, which recognises collaborative working between developers and the community as good practice that should be encouraged.

24 APPENDIX 1

REQUIRED MODIFICATION:

• Delete paragraph 9.38 and modify paragraph 9.39 as follows:

9.38 Policy DD2 requires all development proposals to be of a design quality that respects the character and distinctive appearance of Crudwell Parish by demonstrating how the proposal meets the Crudwell Design Guide.

9.39 Policy DD1 criterion h) requires the Tuners Lane site developer to demonstrate that this is the case to the local community via the Community Liaison Group before a planning application is submitted. The mechanism to ensure that the site remains deliverable is set out above The Parish Council will seek to work with the developer through the Community Liaison Group with the aim of ensuring that the proposals result in a development that respects the attractive and distinctive character of Crudwell, having regard to the Crudwell Design Guide.

R36 Page 22, Page 26 EXAMINER COMMENT: In the interest of clarity. paragraph Paragraph 9.39 94 and page There is no evidence to demonstrate that all of the requirements listed 28 are deliverable and I note that some of the requirements are, for

25 APPENDIX 1

REQUIRED MODIFICATION:

• At paragraph 9.40 delete “requirement” and change first bullet point as follows:

This requirement responds to the following neighbourhood plan objectives:

• To seek to ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately. • To seek faster broadband speeds and better mobile phone coverage in the Parish, especially in the outlying areas and smaller villages.

R37 Page 23, Page 27, EXAMINER COMMENT: In the interest of clarity. paragraph paragraph 9.44 97 and page The words must and should are very different to one another in land use 28 planning policy terms. Must is a requirement, whilst should provides the flexibility to take account of relevant circumstances. At paragraph 9.44 replace “must’ with “should”

REQUIRED MODIFICATION:

• At paragraph 9.44 replace “must’ with “should”:

Policy DD1 criterion i) clarifies that the developers must should deliver fibre-to-the-premises at Tuners Lane, to ensure that homeworking is a viable option for the development’s residents.

26 APPENDIX 1

REQUIRED MODIFICATION:

• At paragraph 9.45 delete “requirement” as follows:

This requirement responds to the following neighbourhood plan objectives:

• To improve promotion and enablement of recycling and waste reduction. • To explore and exploit opportunities for green build standards, renewable energy.

R39 Page 25, Page 28, EXAMINER COMMENT: In the interest of clarity. paragraph paragraphs 114 and 9.49 to 9.53 Also, education contributions are a matter between the Education page 28 Authority and the developer. Notwithstanding that the vague reference to this in Policy DD1 does not have regard to the national policy test for planning obligations, this is not a matter for determination by the Parish Council through the Neighbourhood Plan. Delete paragraphs 9.49 to 9.53 (and associated heading)

REQUIRED MODIFICATION:

• Delete paragraphs 9.49 to 9.53 (and associated heading) as follows:

Requirement 9: Provide funding towards primary school improvements.

27 APPENDIX 1

9.49 This requirement responds to the following neighbourhood plan objectives:

• To ensure that the delivery of new homes is part of an overall plan to enhance infrastructure and community resources appropriately. • To nurture and protect Crudwell School. • To maintain, protect and enhance existing community facilities, especially school, church, local businesses, village hall and open spaces.

9.50 Wiltshire Core Strategy Policy 3: Infrastructure requirements, explains that “All new development will be required to provide for the necessary on-site and, where appropriate, off-site infrastructure requirements arising from the proposal. Infrastructure requirements will be delivered directly by the developer and/or through an appropriate financial contribution prior to, or in conjunction with, new development…”.

9.51 The Reasoned Justification to the policy, at paragraph 4.41, notes that education is considered to be “essential infrastructure”.

9.52 As the primary school is so important to the community of Crudwell and to its character, criterion k) explains that the Tuners Lane development will be expected to meet the costs resulting from the additional primary school children that are expected to live at the Tuners Lane development. This will ensure that this issue is not missed in discussions about competing priorities.

9.53 The requirements above have been transferred into the criteria in policy DD1 below.

28 APPENDIX 1

Modifications required to be made to the draft Crudwell Neighbourhood Plan (2019 - 2026) (submitted May 2020) in response to the Examiner’s recommendations and to correct errors Reference Page in Related CNP Recommendation and proposed modification Reason for modification number Examiner’s page / section Report R40 Page 25, After deleted EXAMINER COMMENT: In the interest of clarity and to paragraph paragraphs comply with the basic 115 and 9.49 – 9.53 Any planning application for development at the Tuners Lane site must conditions. page 28 be subject to an Appropriate Assessment and that mitigation would be required and must be agreed before the application is submitted. Add a new paragraph: “Due to residential development being allocated on the Tuners Lane site and the site being located within the potential zone of influence around the North Meadow and Clattinger Farm Special Area of Conservation (SAC), the allocation may result in additional visitor pressure on the SAC. It is therefore essential that an Appropriate Assessment is carried out and mitigation is agreed prior to any planning application at the site. The Community Liaison Group will seek to support the developer in this regard. It is also noted that it is essential that liaison takes place with Natural England and Wiltshire Council as part of this process.”

REQUIRED MODIFICATION:

• Add a new paragraph after deleted paragraphs (see R40 above) as follows:

Due to residential development being allocated on the Tuners Lane site and the site being located within the potential zone of influence around the North Meadow and Clattinger Farm Special Area of Conservation (SAC), the allocation may result in additional visitor pressure on the SAC. It is therefore essential that an Appropriate Assessment is carried out and mitigation is agreed prior to any planning application at the site. The Community Liaison Group will seek to support the developer in this regard. It is also noted that it is essential that liaison takes place with Natural England and Wiltshire Council as part of this process.

29 APPENDIX 1

REQUIRED MODIFICATION:

• Modify Policy DD2 as follows:

Development proposals must be of a design quality that respects the character and distinctive appearance of Crudwell Parish, by demonstrating how they meet having regard to the Crudwell Design Guide (Appendix 1).

R42 Page 29 Page 30, EXAMINER COMMENT: In the interest of clarity and to Paragraph paragraph 9.56 comply with the basic 119 & 120 Change Para 9.56 (which is supporting text and not a Policy) to conditions. “Policy DD2 recognises the essential role that good design has to play in retaining and enhancing Crudwell’s attractive qualities. The Crudwell Design Guide provides detailed information to guide and support the delivery of high-quality design that respects the area’s local vernacular.”

REQUIRED MODIFICATION:

• Amend paragraph 9.56 as follows:

“On that basis, all new developments in Crudwell Parish must “fit in”, in terms of their layout and the design of the homes themselves. The

30 APPENDIX 1

R43 Page 29 Page 31, EXAMINER COMMENT: In the interest of clarity and to paragraph 9.58 comply with the basic It is beyond the scope of the Neighbourhood Plan to require the guidance conditions. to be “met” by all development, or for it to comprise the tool against which all development will be “judged.” Delete Para 9.58

REQUIRED MODIFICATION:

• Delete paragraph 9.58.

The Community Liaison Group described in paragraph 9.13 would work with the developer to agree a design for the Tuners Lane development, and to ensure that it remains viable given the requirements of policies DD1 and DD2.

R44 Page 29 Page 31, EXAMINER COMMENT: In the interest of clarity and to paragraph 9.59 comply with the basic It is beyond the scope of the Neighbourhood Plan to require the guidance conditions. to be “met” by all development, or for it to comprise the tool against which all development will be “judged.”

REQUIRED MODIFICATION:

• Amend paragraph 9.59 as follows:

31 APPENDIX 1

• To deliver new housing that meets local needs and is community led. • To protect and enhance our natural, built and historic environment, as a rural and agricultural community on the edge of the Cotswolds, by ensuring any new development is appropriately located and of a scale and design sympathetic to its surroundings. • To protect and maintain our green spaces and recreational open spaces • To protect our Conservation area • To explore and exploit opportunities for green build standards, renewable energy

R45 Page 31 Page 34, EXAMINER COMMENT: In the interest of clarity and to Policy IT1 The Policy includes a vague reference to “where appropriate,” without comply with the basic providing any detail as to what will or will not be appropriate and conditions. consequently, this part of the Policy is ambiguous. Further, it is not the role of Neighbourhood Plans to repeat national or local policy and the reference to national and local policy in Policy IT1 is superfluous.

Wiltshire Council has recommended additions to Policy IT1 which add to the clarity of the Policy.

The Neighbourhood Plan cannot impose requirements upon other bodies, such as statutory undertakers. In this regard, I also note that the Qualifying Body is not the Local Planning Authority and cannot dictate planning application requirements.

REQUIRED MODIFICATION:

32 APPENDIX 1

“Policy IT1: Surface Water and Foul Water Drainage

Where appropriate, Pproposals for new development in areas at risk of flooding must be accompanied by a site-specific flood risk assessment, in line with national and local planning policy, and a drainage strategy that demonstrates how flood risk from all sources will be managed without increasing flood risk elsewhere. This should consider all sources of flooding and take into account the likely effects of climate change.

Where necessary, this should assess the impact of flow rates from the site on the whole catchment and consider on-site and off-site measures to prevent any increase in flood risk within the site’s drainage catchment.

To minimise the impact of the development, post-development surface water discharges from the site should provide 20% betterment over pre- development discharges greenfield runoff rates for greenfield sites, and post development discharges to be as close as reasonably practicable to greenfield runoff for brownfield sites.

Major development and development in areas at risk of flooding should incorporate SuDS (Sustainable Drainage System), unless there is clear evidence that this would be inappropriate.

Sustainable drainage systems should provide multifunctional benefits (water quantity, water quality, amenity and biodiversity). Surface water drainage strategies should be developed in accordance with the surface water disposal hierarchy - 1st Re-use, 2nd infiltration, 3rd watercourse/surface water body, 4th surface water sewer, 5th combined sewer. Flood risk assessments and

33 APPENDIX 1

Where developments discharge to the public sewer, flow rates to the sewer must be agreed with the sewerage undertaker (Wessex Water). If alternative foul drainage arrangements are proposed (such as septic tanks or cesspit), the applicant must explain why this is appropriate. “

R46 Page 31 Page 34, EXAMINER COMMENT: In the interest of clarity paragraph 10.14 Delete last paragraph of Policy IT1 (“Where developments discharge…appropriate.”).

REQUIRED MODIFICATION:

• Modify paragraph 10.14, as follows:

“Policy IT1 has been developed based on advice from the Drainage Engineering team at Wiltshire Council, and it seeks to ensures that, when a site is developed, the rate of surface water run-off rate is lower, ideally by 20%, than the existing situation. Policy DD1, which allocates the Tuners Lane site for development, explicitly cross refers to policy IT1 to ensure that the development of the Tuners Lane site will improve the current situation. The development of the Tuners Lane site should improve the current situation. “

R47 Page 31, Page 34 EXAMINER COMMENT: In the interest of clarity and to paragraph Paragraph comply with the basic 126 10.15 The Neighbourhood Plan cannot impose requirements upon other conditions. bodies, such as statutory undertakers. In this regard, I also note that the Qualifying Body is not the Local Planning Authority and cannot dictate planning application requirements. Change Para 10.15 to “Most development will discharge to the existing public sewer. Matters relating

34 APPENDIX 1

REQUIRED MODIFICATION:

• Amend paragraph 10.15 as follows:

As Crudwell is sewered, policy IT1 ensures that any development connects to the existing sewer, and that Wessex Water can influence the rate that foul water enters the sewer to ensure that this will not make existing problems worse Most development will discharge to the existing public sewer. Matters relating to the public sewer are the responsibility of the statutory undertaker, Wessex Water.

R48 Page 31 Page 34 EXAMINER COMMENT: In the interest of clarity and to Paragraph comply with the basic 10.16 The Neighbourhood Plan cannot impose requirements upon other conditions. bodies, such as statutory undertakers. In this regard, I also note that the Qualifying Body is not the Local Planning Authority and cannot dictate planning application requirements. Delete Para 10.16

REQUIRED MODIFICATION:

• Delete paragraph 10.16 as follows:

Should improvements be required to the existing public sewer network to allow the site to be served, the developer should engage with the sewerage undertaker early in the process to allow capacity improvements to be delivered.

R49 Page 32 Page 37, EXAMINER COMMENT: In the interest of clarity and to Policy IT2 comply with the basic Policy IT2 is unnecessary in respect of the Tuners Lane site, as that site conditions. is already considered in Policy DD1. Further, there is no substantive

35 APPENDIX 1

Policy IT2 does not have regard to national policy.

Change Policy IT2 to “The maintenance and enhancement of public rights of way will be supported.”

REQUIRED MODIFICATION:

• Amend Policy IT2 as follows:

Policy IT2: Highway Safety Proposals for new development must demonstrate how pedestrians and cyclists from the development will safely access the parish’s facilities.

Particular consideration must be given to the adequacy (width, surface quality and lighting) of the footway/footpath network between any new dwellings that have the potential to be occupied by primary school aged children and Crudwell Primary School.

Developer contributions will be sought to upgrade the footpath network between the development site and the village’s facilities where this is necessary The maintenance and enhancement of public rights of way will be supported.

R50 Page 33 Page 36, EXAMINER COMMENT: In the interest of clarity and to paragraph comply with the basic 10.18 The Neighbourhood Plan cannot impose requirements upon other conditions. bodies, such as statutory undertakers. In this regard, I also note that the Qualifying Body is not the Local Planning Authority and cannot dictate planning application requirements. Replace Para 10.18 with “The Parish Council recognises that highway safety is a significant concern in the Parish. Whilst this Neighbourhood Plan has no control over Highway

36 APPENDIX 1

REQUIRED MODIFICATION:

• Amend paragraph 10.18 as follows:

The Consultation Statement shows that highway safety is a significant concern in the Parish. This relates both to the volume and speed of traffic using the A429, which runs through Crudwell village, and to perceptions about the quality of footpath network linking parts of the village to the village’s facilities, and to the school in particular The Parish Council recognises that highway safety is a significant concern in the Parish. Whilst this Neighbourhood Plan has no control over Highway Authority matters, the Parish Council will seek to encourage improvements to highway safety throughout the Neighbourhood Area.

R51 Page 33 Page 37 EXAMINER COMMENT: In the interest of clarity and to Paragraph comply with the basic conditions 10.23 and Policy IT2 attempts to require all development to “demonstrate how 10.24 pedestrians and cyclists from the development will safely access the parish’s facilities.” Delete Paras 10.23 and 10.24 and replace with “Policy IT2 encourages improvements to the public rights of way network, to encourage safe movement for pedestrians and cyclists.”

REQUIRED MODIFICATION:

• Delete paragraphs 10.23 and 10.24 and replace as follows:

Policy IT2 elaborates on these policies, focussing on the adequacy and safety of footpath links between proposed development and the village’s main facilities (set out in paragraphs 4.4 to 4.10), and Crudwell Primary School in particular.

37 APPENDIX 1

Policy IT2 encourages improvements to the public rights of way network, to encourage safe movement for pedestrians and cyclists.

R52 Page 34 Page 39 EXAMINER COMMENT: In the interest of clarity and to Policy CL1 comply with the basic conditions The Parish Council is not the Local Education Authority and the long term future of Crudwell Primary School is not something that the Neighbourhood Plan has any control over.

The overall aim of Policy CL1 is to add a layer of protection to an important community facility and is in general conformity with the Core Strategy. However, as worded, the Policy could harm the potential for a community facility to be retained at the site should the school use ever fall away and this would not be in general conformity with adopted local strategic policy. Change Policy CL1 to “…is safeguarded for community use. Any proposals to redevelop any part of the school site for noncommunity uses will not be supported.”

REQUIRED MODIFICATION:

• Modify Policy CL1 as follows:

“Policy CL1: Crudwell Primary School

38 APPENDIX 1

The Crudwell Primary School site, as identified on the proposals map, is safeguarded for educational use. Any proposals to redevelop any part of the school site for non-educational uses will be resisted community use. Any proposals to redevelop any part of the school site for noncommunity uses will not be supported.”

R53 Page 34 Page 38 EXAMINER COMMENT: In the interest of clarity. Paragraph 11.3 The Parish Council is not the Local Education Authority and the long term future of Crudwell Primary School is not something that the Neighbourhood Plan has any control over.

The overall aim of Policy CL1 is to add a layer of protection to an important community facility and is in general conformity with the Core Strategy. However, as worded, the Policy could harm the potential for a community facility to be retained at the site should the school use ever fall away and this would not be in general conformity with adopted local strategic policy. At paragraph 11.3, change last sentence to “The current capacity of…”

REQUIRED MODIFICATION:

• Amend the last sentence of paragraph 11.3 as follows:

“Policy DD1 specifies that an additional 20 to 25 dwellings will be delivered at Tuners Lane. According to Wiltshire Council’s Planning Obligations Supplementary Planning Document, this would result in up to an additional 6 to 8 primary school aged children. These children could be accommodated at the school currently. The current capacity of the school however would be an inhibitor to the village supporting significantly larger developments.”

39 APPENDIX 1

REQUIRED MODIFICATION:

• Delete paragraph 11.6 as follows:

To redevelop Crudwell Primary School would alter the character of Crudwell Village and the conservation area fundamentally so the Steering Group considers it to be important to provide an additional level of protection for the school site, including the playing fields.

R55 Page 34 Page 39 EXAMINER COMMENT: In the interest of clarity and to Paragraph 11.8 comply with the basic Delete second sentence of Para 11.8 (“The list…importance.”) conditions.

REQUIRED MODIFICATION:

• Delete the second sentence of paragraph 11.8 as follows:

The Reasoned Justification at paragraph 6.71 of the Core Strategy notes that “Rural facilities and services are those that benefit the local community such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.” The list does not explicitly refer to schools, so the Neighbourhood Plan makes it clear that the local community considers the safeguarding of the school to be of primary importance.

40 APPENDIX 1

REQUIRED MODIFICATION:

• Modify paragraph 11.9 as follows:

“The policy does not restrict the school from developing additional school buildings if it needs to do so. It is noted that any such changes should conserve the character and appearance of the Conservation Area. to ensure its long term viability but, as the school site (including the playing fields) lies within Crudwell’s conservation area we should show this on the policies map, the design of any new educational development would be controlled by Wiltshire Core Strategy Policies 57 and 58, as well as by the Crudwell Design Guide referred to in policy DD3. “

R57 N/A Whole EXAMINER COMMENT: Consequential amendments document The recommendations made in this Report will have a subsequent impact on Contents, including Policy, Figure, paragraph and page numbering.

REQUIRED MODIFICATION:

• Update the Contents and where necessary, Policy, Figure, paragraph and page numbering, to take into account the recommendations contained in this Report.

41 APPENDIX 1

WILTSHIRE COUNCIL COMMENT:

Reference to the “Draft for Submission to Wiltshire Council” on the front cover should be removed and replaced with “Referendum Version”. and the footnotes on the bottom of each page referring to “Submission Draft Crudwell Neighbourhood Plan – May 2020” should be replaced with “Draft Crudwell Neighbourhood Plan – Referendum Version”

REQUIRED MODIFICATION:

• Modify the text on the front cover of the plan as follows:

Crudwell Neighbourhood Plan - 2026 Draft for Submission to Wiltshire Council

May 2020 Referendum Version

• Modify footnote of each page of neighbourhood plan as follows:

Submission Draft Crudwell Neighbourhood Plan – May 2020 Referendum Version