Sent: 04 March 2016 11:41 To: Staincliffe, Mark; Pearson, Mathew Subject: Rawlings Farm and East of

This email is sent on behalf of the Tytherton Lucas Residents Association. It is sent to OPPOSE the following applications:

Planning Application 15/12363/OUT Chippenham Riverside. Objection. Mathew Pearson Planning Application15/12351/OUT. Rawlings Green. Objection. Mark Staincliffe

1. Premature

This opportunistic application has been presented to bypass the inspectors hearing later this year. The developers hope that by applying for planning permission now they will be able to avoid having to justify their evidence to the inspector. This application should be rejected and the decision should be left to the inspector when he has received a new list of appropriate sites from the council together with the new evidence that he has requested.

In the light of the views expressed by the inspector it would appear that the sites at Rawlings Green and East of Chippenham should be treated as unsound and should not be considered prior to his decision later this year.

Given the fact that there is no adopted or emerging sound policy that can justify these two proposals, limited weight should be given to the CSAP until the inspector makes his decision.

Each site must be treated seperately with no assumption that the other site will be built.

2. The case for the ELR has not been adequately justified

The evidence provided to the inspector relied on out of date evidence and heavily biased scenarios. It also failed to consider a SLR which would link with the A350 which is the key road identified by the council as the economic artery of . The council was asked to obtain new evidence. The inspector also stated that he wished to retain, at the council's cost, his own traffic expert.

The Inspector was concerned that it would affectively act as a bypass and encourage out- commuting which is contrary to the adopted core strategy.

The council has not included in its policy a need for either an ELR or a SLR.

The case for the ELR, according to the developers, is that it will reduce traffic in the town centre. In which case it raises the legal question, which the inspector raised, of how can CIL payments be used to fund improvements not in the site the subject of the application.

3. Is the ELR deliverable?

This depends on Rawlings farm developers building the ELR to the boundary of the East of Chippenham site, Which requires a bridge over the railway. Then it requires C2020 to continue the road down to Abbeyfields School having built a bridge over the Avon for the road and a bridge for the cycle track. As the inspector said it only needed one link in the chain to break and the whole road was not capable of delivery. There is no guarantee that the developers will continue building after the minimum amount required as the next additional house would cost millions and millions of pounds.

This also appears that the link road has a different purpose between the different sites. In the case of Rawlings farm it goes through the houses whereas in the case of east of Chippenham it is the outer boundary. Will the residents of Rawlings green want a bypass running through their houses?

The proposal is not a sustainable development since it fails to address the phasing and delivery of the other developers (it needs East of Chippenham, Rawlings Green and North Chippenham Consortium), especially the link road therein, which is necessary for the development to avoid an unacceptable impact on surrounding road junctions and traffic movements across Chippenham as a whole. Such impact would be contrary to CP3, CP10, CP61 and CP62 of the Wiltshire Core Strategy 2015.

Finally it is not clear from the plans that the end of the road in the Rawlings Green development joins the road at the beginning of the East of Chippenham development. As the plans are final in respect of transport if they do not join then both schemes fail.

4. Number of houses

The inspector was concerned at the number of houses proposed. These 2 sites alone provide 2200 homes. To this must be added any brownfield sites and probably the Crest/ Redcliffe site of 1000 homes as this was the council's first choice. This would result in nearly 4000 houses being built while Chippenham needs to provide 1935. A massive over supply.

C2020 wish in due course to build upto 2600 homes on their site.

As c2020 wish to apply for almost twice as many houses as listed in the CSAP, this casts doubt on the soundness of the CSAP as a whole.

5. Landscape

We have obtained an independent landscape report from WHLandscape Consultancy Ltd which has already been forwarded to you. This report should be given at least equal weight to the report obtained by the developers. Our instructions to the author were not to give us the report we wanted, but to look at it independently and provide his own views. He has made it clear that no development should extend north of the cycle route.

We strongly dispute the evidence provided by C2020 that there will be no noise or light pollution. Also that our views are in effect not disturbed. A letter signed by over the residents has been sent to the council objecting to those statements and making it clear that they object to this proposal.

The proposal would have an unacceptable impact upon the tranquil nature of this part of the countryside, from the setting of listed buildings at Tytherton Lucas as well as its relationship to the nearby village of Tytherton Lucas. This proposal is therefore contrary to the provisions of CP 10, CP 51, CP 52 and CP 58 of the Wiltshire Core Strategy 2015, the NPPF as well as section 16(2) and 72(1) of the Planning (Listed Building and Conservation Area) Act 1990.

6. Air pollution

No tests were carried out in Calne where the NOX levels exceed EU levels. The ELR would exacerbate the levels. We understand the council will be looking at this.

7. Connection to J17 of M4

We understand the council gave its reasons as to why it would have rejected the additional houses at Barrow Farm if an application had been made on the basis of Highways view that no new houses should be built until the junction had been sorted. If a development for 500 homes was rejected on that basis certainly applications for 2200 homes should be rejected.

The application fails to set out a scheme that would ensure the delivery, at the appropriate time, of the necessary improvements to J 17 of the M4 so as to render the strategic road network safe. As such, the application would not meet the requirements of CP10, CP62 and CP66 of the the Wiltshire Core Strategy 2015.

8. Self containment of Chippenham

Out commuters will be attracted to live near to the ELR with access to the M4 and railway station. This is contrary to the core strategy.

The proposal fails to provide a suitable bus strategy so as to demonstrate sustainable connections to Chippenham town, thereby failing to meet fully requirements of policy CP61 of the Wiltshire Core Strategy 2015.

9. Flooding

The assumptions about mitigation of run-off are unrealistic. This is particularly important in the light of revisions to flood risk assessment assumptions currently being undertaken by the environment agency. As development is up stream of Chippenham any error could result in Chippenham being flooded.

29/12/15. David Rooke, deputy chief exec of EA told BBC: "we are moving from known extremes to unknown extremes. We will need to have a complete rethink."

We need to let the EA re-assess its models as otherwise we could find the SuDs were insufficient. Current EA advise may be updated later this year and thus prove not to be robust.

Raising the banks of the Avon as suggested by C2020 could cause huge damage upstream and flood farm land in Tytherton Lucas. This must not be allowed to occur.

10. and Calne

The site east of Chippenham is mainly in the parish of Bremhill. Bremhill in the neighbourhood plan have made it clear that they do not wish to have any substantial development. Their views should be followed. In addition as the development is in Calne CP8 applies, and the number of houses required under CP8 have been exceeded.

At present, there is no Chippenham Site Allocations Plan (CSAP) adopted within the Wiltshire Core Strategy. Therefore this application site lies outside of the limits of development for Chippenham, as defined by Policy CP1 and CP10 of the Wiltshire Core Strategy. While the CSAP DPD can provide input into the application, surely the application has to be judged against only adopted policies and spatial strategies.

Therefore this application should be considered within the only existing policy and Spatial Strategy for this development land, Core Policy 8 Spatial Strategy: Calne Community Area.

1) Plan CP8 calls for 165 homes in the area outside Calne itself. This application is for some 1500 homes, far in excess of the number required in the plan period.

2) This application is not “protecting and enhancing the important ecological value and landscape character of the River Marden corridor” as stipulated in bullet 3 of paragraph 5.41 of the Issues and Considerations of CP8.

3) The application does not identify “an appropriate solution to reducing impact on traffic from the waste facilities located on the edge of Calne” as stipulated in bullet 4 of paragraph 5.41 of the Issues and Considerations of CP8. Indeed it is obvious that an ELR would add to the volume of traffic using the A4 and centre of Calne.

4) The application does not “consider measures” to improve air quality in Calne, particularly in light of the AQMA declared, as stipulated in the final bullet of paragraph 5.41. Again the provision of an ELR provides an alternative route to the M4 to the east through Calne and Marlborough, increasing traffic.

5) This application contravenes paragraph 5.42 of Core Policy 8, in that it goes against the strategy of using the River Marden to provide a “wider green infrastructure network linking Calne with Chippenham and the wider countryside”.

12. Employment led

Development is meant to be employment led. Yet the key employment areas are based on the A350! The amount of land allocated to employment is low. The net result is that home owners will out commute by car or by train. This is in breach of stated policies.

13. Infrastructure

The proposed development fails to provide and/or Secure adequate provision for necessary on site and, where appropriate, off site infrastructure. Such infrastructure shall include, but not be limited to, affordable housing, public transport provision and directly related junction improvements, waste collection and measures for the future maintenance. of the open spaces. This application is therefore contrary to CP3 of the Wiltshire Core Strategy 2015.

14. Village of Tytherton Lucas

I quote below an extract from the council's refusal of Barrow Farm as amended to refer to our village. If this was the council's view earlier this year on Barrow Farm it should be their view on Rawlings Farm and East of Chippenham. Thus both applications should be rejected.

The sites are on the eastern edge of Chippenham, bordered by the River Avon, the River Marden and Stanley Lane. This area is part of Calne Rural and Bremhill Parish. The area has a rural, agricultural feel, and is characterised by open fields with longstanding footpaths crossing them. Both river banks have an abundance of wildlife, and the river Marden has Riparian trees along both embankments. Kingfishers, and many other birds have sanctuary along the banks. Otters, and coarse fish live in harmony. The river is fished by Calne Angling Club and by Chippenham Angling Club. The village of Tytherton Lucas which is a conservation area, is set back from the proposed development by just 400 metres from the north side of the River Marden. The Norman Church of St Nicholas and houses alongside the church are clearly visible from the proposed development. The Church is mentioned in the Domesday Survey of 1086, and a number of houses are of grade II* or grade II dating back to the 15th century. There is an ancient footpath that passes by St Nicholas Church crosses the River Marden at the Ray Anscombe footbridge, and the path crosses the proposed site joining the North Wiltshire Rivers Cycle Route. This is the old railway line that starts in Calne and finishes in Chippenham. This is a valued asset for recreation. The proposed site will be built either side of this track, residents and visitors will lose the valued landscape setting, and fresh air that this open countryside provides. Hardens Farm house is a listed property and will be absorbed into this new development, the heritage and features lost to a modern development. Over 300 acres of farmland and insect habitat will be lost. This will have a severe effect on local bird life and other animals living on this farmland. The proposed development would infill an area of countryside that is many times the size of the Tytherton Lucas conservation area. The buildings will dominate the landscape and be visible from as far away as Lyneham Banks, and the landscape in the River Marden valley would be lost. Development of this scale would necessitate the construction of a substantial road bridge over the River Avon impacting the landscape, damage to the river wildlife and impacting the river flow. Road building will result in the removal of hedgerows, creation of a new junction at Stanley Lane adjacent to a busy secondary school, the impact on the environment and young people cannot be under estimated from the large number of vehicles using this junction. Street-lighting would also need to be introduced, urbanising this rural area and harming it’s character. Whilst it is acknowledged that some additional housing may need to be built, the quantity proposed for this one site is completely out of proportion with the area and does not reflect the scale or vernacular linear built pattern. This development would harm the setting of the heritage assets because the rural character would be removed, the agricultural land that many of the heritage assets were constructed to be associated with will be lost and the peaceful setting urbanised. Removal of hedgerows and historic footpaths, together with expansion of the road would add to the harm caused due to the destruction of this countryside setting. It is felt that the harm caused would be less than substantial but that this harm cannot be outweighed by the public benefit. The proposals would therefore be contrary to the NPPF section 12, as well as section 16(2) and 72(1) of the Planning (Listed Building and Conservation Area) Act 1990 and as such this application should be refused. 15. Support

We fully endorse the objections provided by Helen Stuckey, Kim Stuckey, Ian James, Chippenham town council, Moss Naylor Young Ltd, ADL Traffic and Cause. We agree with all points made in those objections and simply offer our support to those points rather than repeat them here.

Richard Hames Chairman Tytherton Lucas Residents Association Gastons Farm, Tytherton Lucas, SN15 3 RN

Ps. Could you please both confirm receipt.