Land at Widham Farm,

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, SN5 4HQ

1. My name is Richard Pagett, I hold two science degrees and am a Chartered Biologist, a Chartered Water and Environmental Manager, a Chartered Environmentalist and a Chartered Scientist. I have been a resident of Purton since 1986 and I live in Hoggs Lane and so am not directly affected by the proposed development. I am a former chairman of the Purton parish council and retired from leading the Purton Sustainability Group, Ps and Qs earlier this year, after nearly twenty years.

2. I appreciate the need to avoid repetition where possible and, in the interests of brevity, I will restrict my observations mainly to those commenting on the 253 pages of Mr Harris’ proof of evidence, particularly those parts referred to as Propositions 1 – 6. In general, I will also adopt Mr Harris’ text headings to assist orientation between his proof and my commentary.

Growth of Purton 3. The Proof considers that additional growth at Purton can assist in achieving the fourth bullet point of paragraph 28 of the National Policy Planning Framework (the Framework) which is to “promote the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship”. Of course, this is not an argument for housing at Widham itself, merely for housing and so could apply equally in almost any rural village. This is critical to understand because it is widely recognised that some housing in Purton to meet Purton’s need may be desirable. The key to the success of that housing in meeting the aspiration of 4th bullet on paragraph of the Framework is not housing per se, but its location and scale.

4. There is a limited number of shops, and previous housing developments over the years has not led to increased growth of Purton. Housing such as Widham Farm will contribute little to Purton other than more congestion on the oversubscribed roads and out-commuting. In essence Widham Farm would be, simply, a large dormitory, and that is against past and emerging policy.

5. The Proof further notes (paragraph 55 of the Framework) that “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The Proof supports this assertion by quoting part of the Ministerial Forward [sic] to the Framework which states that: “sustainable development is about positive growth - making economic, environmental and social progress for this and future generations”.

6. At this point it is necessary to shine some light on the nature of sustainable development. In 1987 when Gro Harlem Brundtland (a former prime minister of Norway) chaired the group that wrote the first definition of sustainable development it was completely clear that sustainable development was about encouraging human development sustainably, it was about helping millions living in abject poverty to come out of poverty in a sustainable manner by ensuring that social progress, environmental protection and economic improvement were equal contributors. The word “development” was never about (and is still not about, except in the UK) infrastructure. The concept of sustainable development referring to a housing development is a gross distortion of what sustainable development is about. That is why, of course, there is no single example of sustainable development in the UK, anywhere.

7. In fact, worldwide, sustainable development has been demonstrated to be an unachievable aspiration, anywhere. So, it is not surprising that Towards a Green Economy (United Nations Environment Programme, 2011)1 concluded that: “over the last quarter of a century, the world economy has quadrupled….in contrast 60% of the world’s major ecosystem goods and services that underpin livelihoods have been degraded or used unsustainably.” So, there is a mere 40% left for the rest of time.

1 http://www.unep.org/greeneconomy/Portals/88/documents/ger/GER_synthesis_en.pdf

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

8. In local terms, Widham Farm will simply exacerbate the congestion of the limited road network and will have no meaningful access to a public transport network. This site is unsustainable.

9. Let us be clear, sustainability or sustainable development has had its time and has been shown to be completely unachievable. So, when the Proof asserts that “… town and villages should continue to grow and Purton is no exception.” This is pure, self-serving interpretation that has no basis in science, is nothing about sustainability, and is only about turning some land into profit.

10. The Proof does recognise, correctly, that the site is outside the settlement boundary as defined by Policy H 3 of the local plan. This plan will in due course be replaced by the currently-emerging Wiltshire Core Strategy which also sees no reason to change the settlement boundary.

11. The Proof tries to argue of course that “…it is a logical infill site”. Wiltshire Council policy is clear, infill is one or two houses slotted in between existing housing and is expected to be within the settlement boundary.

12. Logically, infill sites need to be within the settlement boundary and, indeed, there are several potential infill sites within the boundary. Widham Farm is clearly not one of them. Frankly, this whole appeal should be dismissed on that ground alone, otherwise what is the point of these boundaries in the first place.

Planning History 13. We must remember that when this land was first put forward during the deliberations of the North Wiltshire Local Plan many years ago (I was chairman of the parish council at the time and remember this well) the Inspector at the time did not allocate the site simply because there were other, better, sites available, as there are now.

14. Despite this clear steer from the planning inspector at the time, the applicant chose to ignore this advice and attempt to gain planning permission some years later in 2009. It was refused and the subsequent appeal dismissed on the grounds that it was outside the settlement boundary and there was no overwhelming reason to breach this boundary. That still remains the case.

15. In complete disregard to the comments of the previous inspectors, the wishes of the parish council and of the local people, the applicant simply turns up again in July 2011 and, after an appeal for non-determination, was again dismissed (decision dated 5th October 2012).

16. The Proof tries rather too hard to suggest that there were no better sites within the settlement boundary. In fact there were and are several. The question is whether or not they are likely to materialise. If one still wanted to harp back to the concept of “sustainability” one does not decide that on the basis of which developer has some land to offload first. If there was any merit in the notion of sustainability, then when a parcel of land comes forward for development should not figure in that decision at all. Such a transitory criterion is clearly a flawed prospect if we are genuinely are trying to build communities rather than simply houses.

17. The Proof concludes this section suggesting that the Wiltshire Council does not have an issue with the scale or location of the development. Yet from the Council’s actual proofs, it does. Consequently, when the Proof concludes “…that the site is an eminently suitable site for development” and it should be a question not should this site come forward for development but rather “…a matter of when the site comes forward…” it is suggesting a context that the evidence simply does not support.

18. How many times do we have to listen to the raising of the Regional Spatial Strategy (RSS) for the South West at these appeals? The RSS was revoked in May this year and no longer forms part of the Development Plan.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

Yet the Proof clutches at the evidence straw that although the emerging RSS has clearly been buried, the evidence base which underpinned the policies of the RSS is still valid. I attended the Examination in Public in Exeter when the RSS was being tested. It was full of flaws and at the time of the demise of the RSS there were still several thousand objections to the Strategy, many of which referred to the evidence base.

19. The Proof argues that the timing of the emerging Wiltshire Core Strategy should be a key factor in this appeal. The Proof complains about the length of the process and that it is unlikely to be adopted until late 2013/early 2014. It then speaks to the Neighbourhood Plan and the likely timescales for that. If the applicant was genuinely interested in “sustainable” approaches to community development, it would simply put its interests on hold and await the emergent Core Strategy and a fully-fledged Neighbourhood Plan. It would then have a robust basis for putting forward its housing interests. However, the applicant does not do this, rather it tries to push forward a development that no one in the parish actually wants before the Core Strategy and before the Neighbourhood Plan are compete. Now, why is that?

20. If the applicant is genuinely interested in community development, the applicant would stand up now and withdraw from this appeal [pause awaiting the applicant]. Hmm, I thought not.

PROPOSITION 1

21. This is about Widham Farm being a sustainable location for an additional 50 dwellings.

22. The emerging Core Strategy recognises that principal urban areas offer the best opportunity for accommodating the majority of future development. That makes logical sense as they have the necessary facilities and infrastructure. Towns (such as ) should be designated to act as Local Service Centres for the wider rural area and Large Villages in rural areas (such as Purton) should provide for local needs, and, importantly should not be developed as dormitories. Housing development in such villages should be limited in scale and to satisfy local need. It also notes that Policy H 3 (Residential Development within Framework Boundaries) should apply.

23. It should be remembered that Large Villages are defined as “…settlements with a limited range of employment, services and facilities..” To those who know Purton, it is clear that Purton is a Large Village. Yet, the Proof attempts to argue that Purton should be re-designated as a Local Service Centre (such as Cricklade). It attempts to argue, with spurious data, that Purton is more self-contained. Anyone of course knows that Purton only has seven shops (six at the top ~ the Istanbul is currently closed and one at the Lower Square) whilst Cricklade has more than 20. Purton does not, as the Proof maintains, have “… all the necessary services and facilities to provide the day to day needs of its residents”.

24. The Proof then proceeds to suggest that the site is available, achievable and suitable. Regarding the availability and achievability, the Proof suggests that the evidence for this is because the appellant has entered into an option agreement with a large house-builder. Recall discussions in the past where such extravagant offers have been made during rampant house-building periods in . Yet thousands of houses still remain undelivered after those permissions with house builders sitting on land awaiting better market prices. Poor delivery of Witchelstowe is good evidence that even the major house builders have difficulty in delivering a site.

25. Turning to the suitability of the site and specifically the environmental and technical aspects of the scheme. Firstly, recall it is outside the settlement boundary and there are far better sites within the boundary. Secondly, the site is not within ready distance (for walking) to the school, pub, the vets, one of the dentists, and none of the chemists, butchers or takeaways. Thus, the site promotes car use. The current bus routes are being consolidated and even in Swindon services are being cut.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

The notion of a bus service being close by to service the site is aspirational. Most residents would not walk uphill for shopping to the one shop within potential walking distance because they would naturally need a car when carrying heavy carrier bags.

26. The Proof notes that both the primary school (St Mary’s) and the secondary school (Bradon Forest) are a further 300 m and 500 m respectively from the junction of High Street and Station Road. It is worth noting that parents in the area opposite Widham Farm take the children to school by car. Therefore, the site is not close to necessary services and facilities to discourage car use. Other sites within the settlement boundary are. The site is simply not accessible to most of the facilities of the village.

27. I will not take up the Inquiry’s time discussing the flooding to which the site is subject. We have spoken about this on numerous occasions and the parish council and our unitary councillor have provided much photographic evidence at the last appeal and subsequently. The photographic evidence is real and testimony of those who know Widham Farm site is real, unlike the comments of the Environment Agency who simply use rather older, generalised spatial projections. We live in Purton and we know what we actually experience.

28. Since the last appeal hearing, Network Rail has released its plans for the doubling up and potential waterproof membrane under the line hence there will be even more water unable to permeate. They have commented in the 2012 application that they will not accept additional water into their culverts. The water that falls onto the fields does not drain into the brook but into the ground so should Widham Farm be built then this water will need to be managed. Establishing a sustainable drainage system requires management in perpetuity and costs in perpetuity. Why build where there will be ongoing maintenance costs for ever. That is certainly not evidence of trying to be sustainable. There are many sites in Purton within the settlement boundary where such constraints and costs do not exist.

29. Turning to Policy T 1 (Minimising the need to travel) of the adopted local plan and Draft Core Policy 61 of the emerging Core Strategy I will say little more other than to re-iterate the actuality of this proposed site in that it encourages car travel. That is plain to understand.

30. The evidence concerning land use fails to grasp the realities of climate change and that because Widham Farm is simply Grade 3 b does not mean that it should built upon by default. In terms of building future resilience, it is imperative that sites for future housing are chosen carefully and with a range of criteria in mind.

31. The Proof concludes Proposition 1 by stating that this site is in a sustainable location. So I must say again, clearly, there is no such thing as a sustainable location. There are sites that may have more resilience. A report published by Ps and Qs earlier this year called Transforming Purton Parish looked at a range of resilience factors and used dependency modelling to establish which of most of the known potential housing sites in Purton were resilient and would add value to the village and the community. Widham Farm scored very poorly. Widham Farm is not a sustainable location.

32. As further evidence for this, the Chartered Institution of Water and Environmental Management (CIWEM) issued a policy document this year: Re-Framing Sustainable Development which commented on the use of dependency modelling in this sort of situation. This was picked up by ENDS (the pre-eminent environmental journal in the UK) who commented very favourably on the CIWEM policy. At around the same time, the Stockholm Institute for Resilience issued a YouTube video calling for the need to re-think sustainable development. Finally, ten eminent scientists also called for re-thinking sustainable development in Nature (a global scientific journal).

33. To call Widham Farm sustainable has no validity.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

PROPOSITION 2

34. Whilst the Core Strategy is emerging, the adopted North Wiltshire Local Plan (2011) and its associated development boundaries are the valid boundaries. Indeed, the emerging Core Strategy maintains this anyway, so Policy H 4 (Residential Development in the Open Countryside) has to be the prima facie position regarding new development in the countryside.

35. Whilst the Proof tries to argue that the settlement boundary is out-of-date, the Core Strategy clearly reinforces this boundary subject to, and only to, any considerations arising during the course of the neighbourhood plan. That the applicant chooses to try to pre-empt matters by continually bringing up Widham Farm before the Core Strategy and the neighbourhood plan are finalised, is a matter for the applicant’s judgement. It cannot be used as a reason to adjust a boundary where it is currently inconvenient. That is planning anarchy.

36. The Proof does try to argue that the settlement boundary is out-of-date because it was based on “historic [sic] housing requirement”. However, I remind the Inquiry that the settlement boundary is to be reviewed during the neighbourhood plan process. The Proof does complains that an up-to-date development plan with revised settlement boundary and potential allocation of land at Purton may not emerge for perhaps 18 to 24 months. Well, that is the time needed to develop the appropriate basis for the future of Purton and which will have the support of the local population (those who know Purton best). It is inappropriate for the applicant to continue to bully the people of Purton with a housing development that most consider to be in the wrong place.

37. There is a clear intent in the Localism Act (2012) to return decision-making to a local focus and the Wiltshire Council. The Wiltshire Council via its emerging Core Strategy clearly retains the intent of Policy H 4 (Residential Development in the Open Countryside) so the applicant needs to try to work local people and their elected representatives during the core strategy and neighbourhood plan process and not be continually unconstructive.

38. The Proof cites various appeal decisions with these decisions included in the Proof’s Appendices. For Feniton (East Devon) what we are not provided with, are emails from Wain Homes that indicate the extent of lack of cooperation with local residents2. At Shavington, the Cheshire East Council was a new council and had not fully completed its Core Strategy so again we see Wain Homes pre-empting due planning process. The Proof argues that these two places are similar to Purton in scale yet Feniton has a railway station and more bus routes whilst Shavington’s case was about the degree of separation between it and Crewe. Neither of these two decisions have applicability to Purton.

39. Reference is then made to the decisions of Moredon Bridge and Ridgeway Farm. These two decisions were about strategic allocations of housing land for Swindon (they just happen to be in our parish). Even those living in the new homes at Moredon Bridge (now called Moulden View) did not realise they were in the parish of Purton when given a survey questionnaire for the recent parish plan survey. Hardly any (if any) completed the form. Moredon Bridge had nothing to do with Purton. Incidentally, the developer has now applied successfully to build a further 50 homes on a nearby meadow of scientific interest. Housing creep is a real problem and we know from this applicant’s statements at a parish council meeting that these 50 houses are just the beginning. The so-called open spaces are simply being left for Phase 2.

40. So, although Ridgeway Farm was granted permission on appeal and is in open countryside, it was judged to be in a strategic housing context (which does not apply in Purton).

41. Widham Farm is not strategic it is supposed to be for local need.

2 http://www.claire-wright.org/index.php/post/email_that_reveals_arrogance_of_wainhomes/ 5 | P a g e

Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

PROPOSITION 3

42. The Proof contends that the release of the site is not premature and will not prejudice the emerging Local Development Framework. Wiltshire Council maintains that it is ~ and surely they should know because they are the government’s planning officers.

43. The policy on prematurity and prejudice is set out in paragraphs 17 to 19 of The Planning System: General Principles and states: “In some circumstances, it may be justifiable to refuse planning permission on grounds of prematurity where a development planning document is being prepared or is under review, but it has not yet been adopted.”

44. Usually, this is taken to mean where a proposed development is so substantial, or where the cumulative effect would be so significant, that granting permission could prejudice the development planning document (which in this case means the core strategy and the neighbourhood plan).

45. I would contend that the issue of prematurity is satisfied ~ the future shape of Purton will undoubtedly be heavily affected by an ad hoc housing development in the wrong location. This is also supported by a finding in the parish plan whereby most people would prefer development to be within the settlement boundary, where it is known that there is adequate housing sites to satisfy local need.

46. The case law cited by the Proof (Cala Homes, Tewskesbury and Truro) concerns far more complex developments than Purton and really has little relevance. The essence of a successful claim of prematurity is that the development proposed (Widham Farm in this case) predetermines and pre-empts a decision which ought to be taken in the development plan (cores strategy and/or neighbourhood plan) process by reason of its scale, location and/or nature. Purton is going to get one chance to define its future shape and that opportunity will be totally ruined by this ad hoc development. The Localism Act and all its aspirations will have been for nought since the applicant’s site at Widham Farm takes away the opportunity for the core strategy and the neighbourhood plan to fulfil their ambitions.

47. Whilst the Proof argues that prematurity and causing prejudice to an emerging plan per se has not been found to be a reason for refusal or for a case to be quashed through the Court, the scale and the stage that the emerging plan has reached are.

48. Whilst the number of houses in the application has reduced during the years down to the now- offered 50 houses this is indicative of let us build something at least. We also know the applicant’s intention is to build more (parish council minutes). Fifty houses may or may not be appropriate I just say let us consider that during a proper thoughtful and consultative process (the neighbourhood plan) rather than during the confrontation style of an Inquiry. This should not be how the future of Purton is decided.

49. The Proof repeats the assertion that “… Purton has the requisite level of services and facilities to cater for the day to day needs of the prospective residents of the proposed development”. This is known to be a fallacy. The emerging core strategy states “…that modest or limited development is appropriate in Purton.” It does not say that this should be outside the settlement boundary. Fifty additional dwellings outside the settlement boundary would be significant.

50. The Proof then complains for the third time that the core strategy and the neighbourhood plan have yet to emerge. A range of circumstances dictate the time for appropriate strategies and plans to emerge, the most important of which is time for consultation. This is a proper planning process.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

The neighbourhood plan is already in progress it cannot and should not be hurried simply to satisfy those impatient to make money from housing.

51. Whilst the neighbourhood plan may need to allocate land to 2026 due to the need to meet open market demand and affordable housing need, it also needs to take account of several factors on which the Proof remains remarkably silent. For instance, the need for 24 affordable homes by 2015 may already be possible through re-configuration of existing affordable housing stock. The neighbourhood plan will be looking at this. Also, with the many potential housing sites within the settlement boundary the neighbourhood plan has plenty of opportunity to steer future development for the benefit of the village as a whole. Thirdly, the neighbourhood plan will look quite carefully at the range and type of houses needed locally.

52. Widham Farm does none of that.

53. Whilst the Proof argues that while the emerging Core Strategy and neighbourhood plan progresses, there cannot be a moratorium on meeting the housing need and demand in an area, it fails to address how, say, the affordable housing will be for local need. We already know, for instance, that any affordable house in Purton is available to the next in line from anywhere in Wiltshire.

54. To conclude this Proposition, the proposed development being outside the settlement boundary would be significant in scale, is premature and undoubtedly is prejudicial to the emerging plans.

PROPOSITION 4

55. The Proof argues that the appeal site should be released now to meet the housing requirement as identified in the existing and emerging development plan.

56. Firstly, this location cannot be considered to be sustainable (thus fails the paragraph 49, NPPF test for reasons given). Secondly, the Policy H 4 currently applies and is reinforced in the emerging core strategy. Thirdly, the continuing reliance on the RSS is tiresome, it was full of flaws when it was going through the Examination in Public and, rightly, has been revoked.

57. To argue that the core strategy has not yet been finalised and therefore we should rely on the last publically-tested housing requirement defies common sense. There was a reason the RSS was revoked ~ it was not fit-for-purpose so to rely on elements of it (because it serves the purpose of the Proof and the applicant) is both illogical and perverse.

58. The Proof is confusing when it argues that because there were substantial objections against the emerging core strategy less weight can be attached to it than if it was complete, yet the Proof relies on the RSS which had thousands (35 000) of objections remaining prior to its revocation.

59. That aside, paragraph 47 of the NPPF requires local planning authorities to “boost significantly the supply of housing” and meet the “full, objectively assessed needs for market and affordable housing in the housing market area”. Allowing the neighbourhood plan to come to fruition will satisfy that objectivity. A quick permission for some houses in a location that is outside the settlement boundary and is non-sustainable is not objective and therefore does not comply with paragraph 47 of the Framework.

60. The Inspector’s decision on the Ridgeway Farm appeal stated: “…there is now strong support for allowing local communities to develop their own DP policies, including housing numbers and allocations, within the overarching requirements of the Framework, which require these policies to be realistic and based on sound evidence”.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

61. The Proof notes that in respect of the five-year supply of deliverable housing sites the inspectors in the various cases cited by the Proof applied the draft RSS as the determining requirement. The RSS is revoked.

62. The Proof consider that determining weight for this appeal should be given to the draft RSS requirement because:

 The emerging Core Strategy is not adopted (but neither was the RSS);  A consultation on main and minor modifications to the Core Strategy is yet to be undertaken (this is hardly surprising because the applicant is jumping in with an application before the core strategy is complete);  The Inspector’s Report is yet to be issued (again, what does one expect if one deliberately submits an application before these matters are resolved);  For the purposes of weight, the core strategy is not further advanced than when the Secretary of State issued the Ridgeway Farm decision in November 2012 (irrelevant since the Ridgeway Farm was for strategic housing and therefore a different context to this application); and,  It has been applied by previous Inspectors over the last four years (the Local Plan was also available over that duration and clearly states no residential development outside the settlement boundary).

63. Of course, Wiltshire Council and the Malmesbury Inspector did consider that the requirement in the emerging Core Strategy should be the requirement when determining the five-year housing land supply.

PROPOSITION 5

64. The Proof then addresses the issue of the appropriate level of affordable housing, financial contributions and undertakings to be made, where they are necessary; directly related to the development; and fairly and reasonably related to the scale and kind to the development.

65. The Proof refers to the Purton Parish Housing Needs Survey (January 2012). If one reviews the questionnaire that was used to generate the results of the survey it is clear that the two parts of the survey were confusing and it is not clear that “affordable” was being used in the planning context, rather than the more universal usage … that which can be afforded by ordinary people. The results are therefore tainted by this in-built bias. Consequently, when the Proof seizes on the result of 90.6% of residents answered yes to a lack of suitable existing housing in the Parish to meet their needs, it is not necessarily about affordable housing per se. The Proof makes an unfounded connection then with the total affordable housing stock in the Parish being 12% which is lower than the Wiltshire social housing average of 19.2%. The parish plan results confirm that this misunderstanding is real.

66. However, the main point is that the neighbourhood plan must be allowed to emerge so that full consultation occurs, particularly with existing provision of affordable housing. There is a strong indication that all the affordable housing needs could be met by a re-configuration of the existing portfolio. There is a significant danger, that if Widham Farm was approved then it would simply be providing affordable housing for others elsewhere in Wiltshire.

67. Of course, any affordable houses should be within the village close to what services there are, rather than on the periphery, away from significant bus routes and outside of effective walking distance.

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Land at Widham Farm, Purton

Evidence provided by Dr Richard Pagett, Huntersbrook House, Hoggs Lane, Purton, Wiltshire SN5 4HQ

PROPOSITION 6

68. The Proof returns to rely on the sustainability criteria in the NPPF. As previously explained, this site is not a sustainable development; it promotes car ownership, it is too far away for routine walking to services and facilities, it is prone to flooding and therefore will be a constant drain on Council resources to mitigate in perpetuity, any construction jobs would be temporary and low value thus not providing much input into the local economy.

69. Indicative of the Proof’s desperation it recognises that whilst Wiltshire Council considers it has a five-year supply, yet the Proof stubbornly announces …” Either way, I consider that there is a need for this site to come forward to ensure that there is sufficient land available in Purton…”

70. The Proof then tries to argue a social role; accessibility, provision of houses where required and supporting strong, vibrant and healthy communities.

71. The site is not accessible and is a car-owning proposition, there is little prospect of meaningful walking other than for exercise. The neighbourhood plan will determine where new housing will go and it will do that through a proper process of consultation and deep local knowledge. The email from BLP Solution who are an estate agent based in Swindon reflects none of that knowledge. The relentless pursuit of the applicant to build on this land does not reflect support for a strong, vibrant and healthy community rather it has been going against the thoughtful opinions of local people, the parish council, the unitary council and the unitary (and previously as county) council for years and years.

72. The Proof suggests that the site has no environmental value because it does not have various Birds and Habitats Directives status or is designated as a Site of Special Scientific Interest; Green Belt, Local Green Space, or is an Area of Outstanding Natural Beauty and so on. Yet it does have value to local people, its open vista, its grazing land, the natural curves of the footpaths and the regular flooding which allows the frequent deluges, which we now experience, to be held prior to discharge to the local watercourses.

73. In summary, the application should be refused because:

 The development is largely inaccessible and is not sustainable;  The neighbourhood plan should determine where our future housing goes and its nature, based on local knowledge;  Affordable homes could be met by re-configuring the existing portfolio;  Land that is less than Class 1 or 2 should not be built on by default;  The site is outside the settlement boundary and therefore is not a logical infill;  There are no demonstrated economic benefits; and,  The process of endless appeals demonstrates the complete disregard of local people.

74. Having regard to the foregoing I respectfully request that the appeal be dismissed.

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