and Broughton Poggs Parish Council Please address all correspondence to the Parish Clerk: Mrs. Christine Hoad, Wynwood Filkins, , Glos. GL7 3JG. Tel: 01367 860388 or 07901 860888 Email: [email protected]

Andrew Tucker Planning and Sustainable Communities West District Council Elmfield, New Yatt Road OX28 1PB

An interim response to the draft LDF

In May 2010, during the previous consultation, this council wrote:

We have now had our Annual Parish Council Meeting, at which the Development Framework was very fully discussed. We also had the advantage of advice from our County Councillor (Don Seale), and District Councillor (David MacFarlane). At a subsequent meeting of the Parish Council, it was agreed that Filkins & Broughton Poggs APM and PC are united in opposition to the concept of any substantial expansion of Carterton on its western boundary.

“We note that such expansion will in effect be a new settlement, since all of it will lie to the west of Shilton Brook which will form a substantial and largely unbridged gap between such expansion and the existing town. Shilton Park is considerably more connected to the existing town, and yet feels like a satellite: this feeling will be even more pronounced with a western expansion. Since any such largescale expansion will have to have the necessary social infrastructure (schools, shops etc), the distance of the new settlement from the old will exacerbate this feeling of isolation from the centre.

“The expansion to the west also makes a mockery of the current axis of commercial development between the town centre and the new retail park towards . This commercial axis makes expansion the East a much more sensible alternative.

“From our position a few miles to the West of Carterton, Filkins and Broughton Poggs' principal objection relates to traffic nuisance. Traffic along the B4477 has increased considerably over the last few years, and particularly since the disparate roads were united and designated as a B road, and shown as a through road on maps and atlases. The road system to the north and east of Carterton has been substantially upgraded, whereas to the West and South the redesignation of the road has been more or less the only change! The B4477 also runs through Filkins, whereas it is now possible to get from Carterton to the A40 without going through another village. The traffic along the B4477 will probably rise with the closure of the Lyneham RAF airfield; more traffic from a West Carterton development would be insupportable.

“We believe that the Shilton Brook forms a natural boundary to the west of Carterton, and should not be crossed.”

Almost a year later, nothing has happened that would lead us to change our mind.

Your own SHLAA updated as recently as January 2011 clearly follows the line that largescale development outside Carterton’s boundaries cannot be justified until a great deal more has been done to develop underused land within the town, and indeed identifies several such areas with approval. Equally the SHLAA points out the huge detrimental effect that development across the Shill valley would have on the setting and approach to Carterton itself, as well (obviously) to the surrounding villages. The SHLAA actually cites the planning inspectors damnation of the suggestion of encroachment into the valley 2005, and suggests no reason why that damnation should be lifted now. It seems unlikely that the present plan to throw a bridge across the Shill Brook to smear 1000 houses across Downs, thereby incorporating the hitherto inviolate valley into the town itself, would find favour with the next inspector. (It is worth adding that elsewhere in the SHLAA the 2005 inspector’s views are certainly still taken as current, eg 1.14)

We take no particular view on the merits or otherwise of the East or North Options (except in so far as we believe that the consultation process has been fatally flawed), but believe beyond doubt that if best planning practice was to guide the LDF, the Shill Brook would remain the boundary of the town. There is nothing new in the latest SHLAA or the proposed LDF that could possibly persuade an inspector or anyone familiar with the terrain otherwise. 1.32 in the SHLAA finishes:

Further sizeable expansion would need to demonstrate that high quality sustainable development could be delivered which would, on balance, justify current planning objectives and policy. On the basis of this technical assessment, there is considered to be potential for a small extension only to the north of the town on land south of the existing allotment.

When the writer says ‘technical assessment’, one rather assumes we are meant to read ‘proper professional planning assessment.’ So why then has the West Option been peddled so assiduously by WODC in the draft LDF? As Lewis Carroll might have said, the reason for this is quite clear: there isn’t one. At least not a planning reason. There seems to be a dimension to this part of the LDF that can not be explained except in terms of wilful political interference. That politics should play a part in the LDF is unexceptional, but it is not acceptable to pretend otherwise. The SHLAA seems to be an honest attempt by WODC professional planners to wrestle with the ‘Carterton problem’, ie how to bring order to an urban mess. The draft LDF reduces this to a crude and simplistic choice between East and West Options. The reasons are clear and not very worthy.

WODC seeks to build a lot of houses, and, possibly uniquely for a town of its size in the south of , Carterton is willing to take whatever is thrown at it. CTC have the curious notion that if it keeps expanding, sooner or later the collection of shops and public buildings on the cross roads will turn into a proper town centre. At a recent public meeting in Filkins, many present who have lived here for decades said that considering how much Carterton has expanded, its shopping centre has not developed in step. Plans to develop on the recreation field came to naught, individual shops have simply been rebuilt as they stood, there is little of aesthetic merit, and one can still see people walking round the town looking for something to buy.

A prime example is that for some years the market site has been a desolate, fly-blown tip, even though largely controlled by people in or connected with Carterton. Can one imagine this happening in any other local town?

CTC’s own discussion document on the draft LDF is shot-through with the belief that all development is good development for with it will come a commercially successful town. There is no evidence to suggest that this has happened in Carterton’s recent past, nor will happen in the future. This council believes it would be outrageous for WODC to bury Alvescot Downs under concrete on such specious grounds.

Although not affecting this parish directly, the Shill Brook carries a lot of surface water away from the town, and the larger areas of hard standing associated with the development of recent years has already put the water course under strain. West Waddy have indicated that as a result of developing Alvescot Downs much would need to be done to protect villages downstream. But we understand that WODC engineers have said that massive new infrastructure is required on Shill Brook even if further development does not take place. A cynic might suggest that WODC would allow development simply to ensure that the developer pays for all the infrastructure, including that required even without the development. We trust that this is not in WODC’s minds.

What does affect this parish directly is traffic, and West Waddy have already told us that there would be significantly more traffic on local roads, and specifically along the B4477 through our parish. The only figure we have yet had from West Waddy is ‘two more cars per minute at peak times’, but absolutely no guidance as to daily increase, nor the methodology used to prepare this figure. Neither were they aware of the traffic survey done last year by this parish council under the auspices of Thames Police and WODC which already shows a significant increase of traffic since the last survey in 2006. We have heard from some quarters that should the traffic continue to grow apace, perhaps the solution would be to widen and upgrade the B4477 to A road status. This would be totally unacceptable to us.

Both the draft LDF and SHLAA assume that most of the new residents in Carterton will be travelling West and North to work, but there is again absolutely no statistics or methodology, and we can make no judgement. What is clear is that the SHLAA, draft LDF and West Waddy have taken no account of the continually changing assessment of the impact of the Lyneham move on traffic between the West and South, and Brize Norton. The timing of the development of the MOD estate in Carterton is subject to constant review, and must be properly taken into account when considering any further development on the West of the town. Frankly, we believe it would be reasonable to rule out any possibility of development West of Carterton until the MOD estate is fully rebuilt and all the effects of planned growth at Brize Norton assimilated.

Filkins & Broughton Poggs is also extremely worried by another aspect of development on Alvescot Downs. So long as the Shill Brook was thought to be the natural boundary of the town, any development on the old Broadwell airfield was ruled out at least partly because of the distance from other settlement. However, if Alvescot Downs is developed, the boundary of the airfield is but two small fields away, and it seems inconceivable that there would not be a clamour from CTC and others to allow Carterton to sweep west towards the A361. The only sure way to prevent this is for you to continue wisely to uphold the Shill Valley as Carterton’s natural boundary.

There seems to a general perception that planes using Brize Norton currently veer north when possible to avoid flying over Filkins (and for that matter Alvescot), and we therefore avoid the worst of the noise. It seems very likely that large scale development on Alvescot Downs would, on Benthamite grounds, encourage the RAF to instruct pilots not to veer north, and in consequence we would have to endure higher noise levels. This is something that the draft LDF does not touch upon. In fact the whole aspect of Brize Norton is somewhat patchily explored in both the SHLAA and draft LDF (see comments above ref Lyneham traffic.) WOIDC also accept with touching faith the RAF’s timescale for replacing noisy planes with quieter ones: in the context of past promises and current cuts, this seems a touch optimistic.

We now turn to the current consultation process. This council has written before pointing out the inadequate preparation, the fact that key protagonists have not known what was and was not on offer, and the bizarre nature of WODC guidance. Even the central CTC in its consultation document says that town councillors had not been aware of the North Option until ‘a very late stage’, and WODC officers suggested quite preposterously that consultees can legitimately ignore the clear unambiguous East/West choice question and write in the North option or any other preference. What possible merit could results from such a consultation have without clearer guidance?

There is also the fact that West Waddy came to Filkins and told us categorically that all landowners of the West site had been consulted, and all agreed with the West Option proposals. We now understand that that this is incorrect and at least one land owner did not know about the scheme at all.

Our first-hand experience is that even Carterton residents do not know what is being proposed in their town, and CTC bases its consultation document on returns from just 71 replies to its canvass. Not content with this, CTC then voted for the West Option even in advance of your consultation exercise. We appreciate that CTC is not the planning authority, but its antics have not helped. The promoters’ half truths and lack of hard information about the effects of development, and your somewhat louche conduct of the consultation coupled with the clear mismatch between the SHLAA and draft LDF have compounded our unease.

We held a public meeting in our village hall recently, and had more people attending from a village of 450 than CTC could muster from 16,000. The mood was undoubtedly against the West Carterton satellite development, but equally people wanted hard facts… About traffic, about noise, about flooding. We understand that WODC is working with West Waddy to produce reports on these and other crucial matters by Mid March, and we believe that only with these reports might there be any basis for a proper discussion about the merits of the Carterton Options. (During our public meeting, West Waddy indicated that this information would be available around mid March.)

We therefore lodge this letter as an interim response to the consultation, and accept your kind offer of an extension of the consultation period for a further two weeks. We hope that during that time you will be able to ensure that we are given the information we need to offer an informed final view of this draft of the LDF. We would be pleased to have your confirmation that the necessary information will be forthcoming.

As part of our final submission, we will also be lodging the correspondence we have had with various officers and WODC councillors and their responses, and also comment on other aspects of the LDF beside the possible expansion of Carterton.

Best regards

Richard Martin Chairman: Filkins & Broughton Poggs Parish Council