Responses to Question 22 – Any Other Comments Please note that this document should be read in conjunction with the Consultation Statement January 2012 Report and the User Guide for the Record of Comments. It should also be noted that the majority of these comments concern a particular issue or are related to section of the Core Strategy. A column has been added to this record of comments to indicate what the overall comment concerns, as well listing issues and cross referencing comments. ‘Comment by’ list which part of the Core Strategy the comment mainly addresses.

Cross Comment No. Comments Officer Comments Issue Reference By

In summary simlify the strategy - if it cannot be communicated to normal people in 10 minutes of speech or at most on 2 sides of A4 we are wasting everyones time because it will not be taken on board. Strategy should describe where we need to be and provide a road map on how to get there. The top level policy issues need to be simplified. Policies 6.2, 6.5, and 6.10 are all Noted. It is recognised that the document can be about protecting and improving our environment - the beautiful countryside which is out unique difficult for non-planners, nevertheless the Overall 4 selling point. Protection of our countryside is an enduring necessity in good times and in bad. If Q22 document carries legal weight and needs to stand Strategy we damage this aspect then the county will exist in name only. Policies 6.6, 6.7, 6.8, 6.9 are all up to scrutiny. about the built environment and infrastructure we can make mistakes in this and therefore permit more risk - errors here can be corrected. To clarify thought I suggest that the division above produces 2 top level objectives of policy prioritised in the order 1. Countryside; 2. Buidings and infrastructure.

Comment noted. Agree that the council did not There is a false statement that needs correction in South Wiltshire Core Strategy - Topic Paper take forward the first two options. The topic 3, Addendum 2. In the section concerning preferred options, Paragraph 5.12 states that: Paper forms part of the evidence base rather than Analysis of consultation responses, including from Statutory Consultees, identified strong the core strategy itself and therefore at this stage South South 16 objections to the first two scenarios, and the Council did therefore take them forward as it is not felt critical that this is amended. The Wiltshire Wiltshire Preferred Options. However, it is a well-known fact that the Council did not take forward either SWCS is at a more advanced stage of of the first two options. production. The council is awaiting a binding report from the planning inspectorate. Noted. The objector is correct in that the plan does focus on new employment land. However Thank you for the work that has gone into this plan. I've looked at it from a very narrow CP21 and CP22 attempt to support existing viewpoint - as a director of a business based on the Canal Road Industrial Estate in businesses. These will be looked at again. In Trowbridge. Strategic objective 1 focuses on the need to have jobs within Wiltshire (deliver a addition, separately from the planning system, thriving economy which provides a range of job opportunities) however the details for this the council is supporting a superfast broadband 17 objective appear to be on developing opportunities for new jobs and says little about helping project, so that more residents and businesses in SO1 businesses already in place. For us, and many other businesses, the local infrastucture is a Wiltshire can benefit from the fastest broadband severe restriction on our development and our competitive position. It would be useful to available. The council has set a target of giving consider the infrastructure requirements to support existing employers to develop as well as 85 per cent of premises access to superfast those needed to secure new employers. broadband by 2015.

Cross Comment No. Comments Officer Comments Issue Reference By

Thank you for inviting me to comment of the County Wide Core Strategy Development Plan. As this is going out for full public consultation I would like to make a request for consultation documents to be in plain simple English. Even the departmental title Spatial Planning is not a Comments noted. Every effort is made to ensure readily understood in the public domain. May I suggest that the following description be added the document readable and understandable to all. to your consultation documentation. The Government has defined spatial planning as 'going References are made to the National Planning Consultation 19 beyond traditional land use planning to bring together and integrate policies for the Q22 Policy Framework and what it means in the document development and use of land with other policies and programs which influence the nature of document and it is considered that not further places and how they function.' In practice this means that the process is very different from the amendments are necessary. Local Plan. It provides planning authorities with an opportunity to take a fresh look at their areas, develop strategic approaches to planning that will deliver sustainable development and reflect the local distinctiveness of the area and the aspirations of the local community.

Thank you for your e mail. But word on the street is that every consultation is pointless and a waste of time and money. Whatever it is you want to do , it is will go ahead regardless of how Consultation 20 Noted. Q22 many valid objections are raised. It is basically a talking shop with a one way street at the end. process As our Dear Maggie, said this lady is not for turning, neither are any of the planning committes.

Wiltshire Core Strategy DPD Thank you for consulting The Coal Authority on the above. Having reviewed your document, I confirm that we have no specific comments to make on this 24 Noted Q22 document at this stage. We look forward to receiving your emerging planning policy related documents; preferably in an electronic format.

Thank you for contacting the Vale of White Horse Council about the Wiltshire Core Strategy 25 June 2011. The document has been considered at officer level and its spatial planning Noted Q22 approach raises no concerns for the Vale. Thank you for consulting Oxfordshire County Council on above document. We do not have any 35 Noted Q22 comments to make. You should be aware that your Core Strategy is already causing hardship and difficulty in Salisbury. I refer to, "Memorandum of Information, The appointment of a Development Partner for Central Car Park and the Maltings, Salisbury.'' This document has a forward by Jane Scott, Leader, Wiltshire Council, and Sir Christopher Benson, Chairman, Salisbury Vision. In this document, the area for development is outlined in red. Within the outlined area are seven residential flats known as, The Maltings, which are above shops and over-look the river. These flats are owned and occupied by elderly residents whose average age is about 84. Because of Noted. The comment will be forwarded to the the uncertainty of these flats in any future development, the old people are unable to sell their South South 36 Salisbury Vision so they are aware of your properties. Two agreed sales have fallen through already and I understand that one estate Wiltshire Wiltshire concerns. agent has refused to handle the flats. The flats are lease-hold, and in 2007 Land Securities purchased The Maltings. Both Salisbury Vision and Land Securities are unable or unwilling to tell the residents whether their properties will be developed or not. Development may involve compulsory purchase orders. The result is that these old people are in limbo and are unable to sell their flats to move into nursing homes or to live closer to their families in their last years. What is needed is clarity. A letter from Wiltshire Council stating that the flats will not be developed and a redrawing of the development area to exclude the flats would be ideal. Cross Comment No. Comments Officer Comments Issue Reference By Dear Cllr Clark Herewith, as requested, our report read out at last night's seminar when the Localism Bill and the Core Strategy were discussed: "We would like to thank Wiltshire Council for holding this meeting on Localism and the Core Strategy. Thank you very much. For too long the people of Trowbridge and villages have seen planners neglect the town centre while allowing developers to cover more and more green fields with housing estates and business parks. All this, while the centre of town stagnates. At last, the people of Trowbridge and villages have a voice and we are delighted! Trowbridge offers so many opportunities --- it has very many brownfield sites to build on, old buildings to convert, industrial areas to modernise. It has many beautiful and historic buildings which are hidden gems of the town, also some excellent new developments in Bradford Road (Park View and Waterside Mews), and the flats on the corner of Timbrell Street and Prospect Place. It has a station with excellent rail services to 57 CP7 Noted. General Trowbridge many parts of Wiltshire, Bath, Bristol and more. " Campaign for a better Trowbridge" looks forward, at last, to a development plan in the form of the Core Strategy and Local Development Framework that builds and renovates the town centre with offices, shops, education and other activities in the town, and that says once and for all a resounding "NO" to just adding more urban sprawl with the idea that "bigger is better",when it's not! In the case of Trowbridge, the sprawling expansion just hasn't worked! Many of us want a County Town and not another Swindon! (in other words ----- Please dont "SWINDONISE" Trowbridge!) Trowbridge could suffer with having more growth than anywhere else in the West Country, if we are not careful, so we would like to ask Wiltshire Council to assure us that there will be an option within the forthcoming Core Strategy for LOW GROWTH!" For and on behalf of "Campaign for a better Trowbridge" Mr K J McCall ACIOB Currently Parish plans are adopted as supplementary planning documents and are already a material consideration in the planning Dear Sir/ madam, Limpley Stoke Parish Council have reviewed the above plan and are process. Given the different scale of the encouraged by its content, in particular the commitment to "protect and enhance the River Avon documents there is unlikely to be conflict between corridor". We strongly recommend, however, that this document explicitly states that each the two documents and both should be Neighbourhoo 67 Community Area Strategy will take into account their respective Parish (or Village) Plans, which Q22 considered when deciding on applications. Where d plans smaller villages such as ours have spent considerable effort in developing and executing, as Neighbourhood Plans differ from parish plans is well as "Neighbourhood Plans". Yours faithfully, Simon Coombe ChairmanLimpley Stoke Parish that they will form part of the statutory Council development plan. Existing Parish Plans will continue to form part of the development plan and are likely to be the basis of Neighbourhood plans. Noted. The approach and definition of development at large and small villages is being Luckington Parish Council would like to see the following in the core strategy - Clarification of reviewed. Nevertheless, the removal of 68 the settlement boundaries to prevent any development outside the existing settlement Question 1 settlement boundaries at small villages is not boundaries in small villages. designed to see development beyond current boundaries. Cross Comment No. Comments Officer Comments Issue Reference By The Shaw Residents Association (SRA) of West Swindon is pleased to note that the Regional Spatial Strategy (RSS) has been abandoned by central government. The Core Strategy that has replaced it promises to give more accountability to locally elected representatives and an improved model for local residents to have an input into any development proposals. This is good for local democracy. The SRA is particularly pleased with the comments on page 73 of appendix 3 (annex 3) of the Core Strategy. This page states that the area known as the “West of Swindon” will not be subject to any further development within the Core Strategy over and above the 200 homes already being built at Moredon Bridge. We note that you reference the application for development of Ridgeway Farm and state that should this application be approved this will be over and above the housing numbers assigned in the WCC Core Strategy. On this subject, the SRA would like to note that of the more than 1000 responses sent in relation to this application, 100% of them are against the development. There are a number of additional references in the Core Strategy that are considered positive by the SRA and serve as additional reasons to ensure the planning application for Ridgeway Farm is rejected. Below are some examples of Core Strategy quotes with SRA commentary: “Strategic objective 1: to deliver a thriving economy which provides a range of job opportunities”: Development of Ridgeway Farm would not provide any long term job opportunities for the people of Swindon. Indeed, your Core Strategy rightly proposes bolstering job opportunities in WCC towns such as Wootton Bassett. Any development of Ridgeway Farm cannot support this objective. “Strategic objective 4: - to build resilient communities”: Locating a WCC development onto at the very edge of Swindon Borough Council (SBC) land will mean revenues from this development go to WCC whereas many of the costs in supporting this community will effectively be borne by SBC. Noted. The situation regarding West of Swindon As such any investments in integrating such a community into the wider Swindon community has changed following the intended abolition of will take a low priority given the revenue / cost profile. This does not help build “resilient the RSS by Government, with less development communities”. “Strategic objective 9: to ensure that infrastructure is in place to support our now being proposed there, as the respondent communities”: Any development of Ridgeway Farm will have a catastrophic impact on local notes. The Core Strategy, has adopted this Development infrastructure, especially road links. Mead Way is already congested and is the only possible Wootton 88 position following comments from the community, to West of access point for this proposed development. “Strategic objective 10: to minimise the risk of Bassett more recent research and in close consultation Swindon. flooding”: Much of the Ridgeway Farm proposal lies on or near a flood plain. “The strategic with Swindon Council. The strategy is serious location of Wootton Bassett and low number of jobs compared to the population provides an about maintaining the openness of the opportunity to expand the employment base significantly. Therefore Wootton Bassett will be the countryside and protecting the identity of the location of strategic employment growth to help reduce out commuting”: Any development of villages outlying Swindon. Ridgeway Farm has the potential for 100% of the residents commuting out of WCC into Swindon. This seems contrary to the intent within the Core Strategy. “The community area may be seen as being at risk from unchecked expansion of the nearby higher order centre of Swindon. Imposition of a rural buffer as a line on a map is not permitted in a Core Strategy by Government guidance. However, protecting the open countryside, as well as the uniqueness of individual settlements, both of which the Core Strategy recognises are prized objectives by the local community, are therefore an important objective for this strategy and will be taken forward by appropriate and strong policy mechanisms”: Any development of Ridgeway Farm clearly flies in the face of this statement. “The separate identities of towns and villages within the community area need to be safeguarded to prevent their coalescence with Swindon”: Development of Ridgeway Farm will ultimately lead to the coalescence of Swindon with Purton. “Housing growth in the main settlements will help improve their vitality and create a critical mass to deliver improvements in infrastructure. However, given that there are a number of existing outstanding housing commitments; future housing growth in Wootton Bassett should be phased to enable infrastructure delivery alongside housing growth”: The SRA is very supportive of such statements and trust that such a view will be applied to the Ridgeway Farm application. In summary, the SRA welcomes the Wilshire Core Strategy as it pertains to the community areas of “Wootton Bassett and Cricklade” and the area known as “West of Swindon”. Based on the reasons documented above and supported by your Core Strategy, the SRA is very much against any development in “West of Swindon” outside of the proposals outlined in the Core Strategy. Thank you for consideration of our comments. (West Swindon based Shaw Residents’ Association (SRA) provides a forum for the residents of Peatmoor, Sparcells, Nine Elms, Cross Comment No. Comments Officer Comments Issue Reference By Middleleaze, Shaw and Ramleaze to work with statutory authorities, voluntary organizations, businesses etc to protect and improve the environment and facilities for residents. http://www.shawresidents.org.uk/ email: [email protected] )

Wiltshire Core Strategy We understand that "Working towards a Core Strategy for Wiltshire‟ builds on the "Wiltshire 2026 - Planning for Wiltshire's Future‟ consultation which was undertaken in 2009/10, and previous consultation exercises undertaken by the former district councils of Kennet, North Wiltshire, Salisbury and West Wiltshire. Before responding to the 91 Support Noted. Vision Q22 specific questions that are asked in the current consultation, we wish first to state that the College supports the Vision for Wiltshire “…to create stronger, more resilient communities” (para 1.5 and as set out in the Wiltshire Community Plan 2011 – 2026: People, places and promises) and, in principle, the Spatial Vision for Wiltshire.

Strategic Objective 3 One of the six key challenges in Wiltshire is delivering new homes (para 2.17), with Strategic Objective 3 providing further direction; it seeks “ to provide everyone with access to a decent, affordable home ”, with the supporting paragraph (para 3.6) reading: “This strategy makes provision for around 37,000 new homes in Wiltshire up to 2026. It sets out a plan for an appropriate mix of types, sizes and tenures, particularly to address affordable Topic paper 17 paper sets out the progress made housing needs and will ensure a continuous supply of housing over the plan period that is in determining an appropriate requirement and aligned to job growth and delivery of infrastructure.” We welcome Strategic Objective 3. distribution of housing for Wiltshire from 2006 to However, in light of the CALA Homes Court of Appeal judgment [1] that emerging development 2026 to inform the draft Wiltshire Core Strategy. plan documents must continue to be drafted in general conformity with the relevant Regional This process considers the strategic objectives for Strategy, it would seem that the level of net additional housing for which provision should be the county as well as taking into account local made (i.e. “around 37,000 new homes”) needs revisiting. Regional Planning Guidance for the factors and aspirations for growth identified South West (RPG10) was first published in September 2001 and sets out the planning strategy through community consultation. Further work on for the South West region up to 2016. Following the introduction of the Planning and the viability of CP28 will be undertaken for the 92 Question 2 Compulsory Purchase Act 2004 RPG10 became part of the statutory development plan and submission draft of the core strategy. This will renamed as the Regional Spatial Strategy (RSS). Policy HO 1: Levels of Housing Development determine the deliverability of this policy. It is not 1996 – 2016 sets Wiltshire a provision of 3,000 additional dwellings per annum. The 37,000 considered appropriate to allow inappropriate figure proposed in the “Working towards a Core Strategy for Wiltshire" public consultation development to take place within the Green Belt, document equates to 1,762 additional dwellings per annum. Strategic Objective 3 – Key this is emphasised within PPS2. Further evidence outcomes Whilst, in principle, we support providing everyone with access to a decent, will be prepared for the submission draft of the affordable home, we consider that this objective, by reason of the key outcomes it seeks to core strategy to clarify the deliverability and achieve, is too prescriptive and onerous in the current market. We therefore promote viability of core policies relating to onsite amendments to three of the key outcomes, as follows: “The strategy has addressed the shortfall renewable energy requirements. in affordable homes across Wiltshire through” being amended to read “The strategy has addressed the shortfall in affordable homes across Wiltshire through ensuring a minimum of 40% of such homes have been delivered in all new schemes of 15 or more houses and 25% on developments of 5 to 14 houses negotiating a minimum of 40% of such homes have been Cross Comment No. Comments Officer Comments Issue Reference By delivered in all new schemes of 15 or more residential units and a minimum of 25% on developments of 5 to 14 residential units taking into account the individual circumstances of the site and economic viability ” ; and “Development will have avoided encroachment on the Wiltshire Green Belt except in exceptional circumstances ”. “All development will have been low-carbon or zero-carbon demonstrated that it has minimised onsite carbon dioxide (CO 2 ) emissions by using less energy, supplying energy efficiently and using onsite renewable energy generation with any reduction target achieved unless it can be demonstrated that such provision is not feasible ” . [1: R (CALA Homes South Limited) v Secretary of State for Communities and Local Government (No. 2)]

With regard to Question 22 we refer here also to our comment on Strategic Objective 3, above. As we continue to promote Polebridge Farm/land east of Duck Street (approximately 37.5 hectares) and land west of Hill Road (approximately 16 hectares) for residential development we request that we are consulted on the Site Allocations DPD; the Affordable Housing SPD; All consultees will continue to be informed of all Further 99 and the Landscape Character Assessments single set of guidelines when views are sought on future planning DPDs at every stage if they have Q22 Consultation these documents. We trust that our representations will be taken into account as the Council indicated this in their preferences. progresses its Core Strategy and other emerging Local Development Framework documents, including the aforementioned. We would be grateful if you would acknowledge receipt of these representations, which we reserve the right to amend or alter.

I believe that the document does not exhibit enough ambition. It does not seem to have been compiled by someone with a true love of the County. In particular it seems to have been accepted that thre current poor financial situation will continue up to 2026. This seems Overall 101 extremely pessimistic. As I travel around the country I see communities achieving much more Noted. Q22 Strategy than we have in Wiltshire over the recent years. In particular new road schemes remove traffic from residential areas and aid commercial development. Very little of this appears in our Wiltshire Plan.

Comments noted. Every effort has been made to In view of the implications of the proposals on the County I feel that your single day exhibitions ensure that as many people as possible are in each of the towns are not sufficient. For example, I am interested primarily in Trowbridge and aware of the Core Strategy and have the yet I cannot make your single exhibition day. If you are truly searching out the views of as many opportunity to comment on the proposals. This Consultation 107 Q22 people as possible I would have expected more publicity and that 3 or 4 days in each town includes via the local media, web and process would have been more appropriate. Fortunately I have knowledge of the availability of the consultation events. Consultation events are document on line and the stamina to read through it. arranged across Wiltshire. It is not possible to have 3 or 4 day events in each town. Cross Comment No. Comments Officer Comments Issue Reference By

3.1 noted, but the spatial vision seeks to improve 3.1, Spacial Vision I feel that there is a contradiction here as, if development is “focused the self-containment of the main settlements principally on Trowbridge, Chippenham and Salisbury” it cannot be said to be sustainable, as thereby providing greater opportunities for living, longer travel distances could be encouraged. Perhaps you need a better form of words to get work and leisure without the need to out your meaning across to readers. 3.2 Strategic Objectives These are difficult to argue with 3.11 commute. It’s therefore about improvement, not Strategic Objective 9 As far as I can read, there is no explanation of how “Strategic transport necessarily a cure. Strategic transport corridors corridors within Wiltshire will have been safeguarded”. Safeguarding Lines were dropped are main arteries shown on the Area Maps and 108 decades ago. 3.12 Key Outcomes Co-ordination with developers is a good idea, but with so Chapter 3. Q22 the plan will not allow development that could many different developers wanting to build in a fairly restricted area, the task of co-ordination prejudice the reliability of these routes and major will be a very difficult one. Will the Council have the numbers of staff in place with the development will need to show how its impacts necessary training, experience and ability to deal with hard nosed developers? I feel that past can be mitigated. The Council is resourced to performance does not fill me with confidence. 3.13 Key Outcomes The use of SUDS means deliver this strategy. Yes impact the Core strategy that a lot more water will be lost to evaporation. Has consideration been given as to how this has been produced in liaison with Natural might affect our rivers and aquifers? England and the Environment Agency.

Comments noted. The Core Strategy proposals are supported and justified by evidence set out in the Topic Papers. Evidence gathering is ongoing and further work will be taking place to ensure Bishops Cannings Parish Councillors have read the Wiltshire Core Strategy Development Plan they are as up to -date as possible to ensure that document and have discussed the content. BCPC considers that the document is so empty of Consultation 119 the Core Strategy is a sound document. Every Q22 sufficiently detailed content that an adequate response is impossible. There also appears to be document effort has been made to ensure that as many a lack of an acceptable level of publicity on the document and its contents. people as possible are aware of the Core Strategy and have the opportunity to comment on the proposals. This includes via the local media, web and consultation events.

No mention is made about the potential impact of Neighbourhood Plans and the willingness of the Wiltshire Council to take these into proper account. The Localism Bill intends that local communities should be able to influence future planning decisions affecting where they There are numerous references to live. Omitting reference to this from the foreward suggests that the Wiltshire Council are only Neighbourhood Plans throughout the document Neighbourhoo 128 Q22 paying lip service to this government objective. As it is, the impression is being given that and it is made clear that Council intends to use as d plans Wiltshire Council are intent on getting the Core Strategy completed before the Localism Bill intended in the Localism Bill. receives Parliamentary assent after which it will no doubt be argued that no further changes will be considered. I trust this is not the case.

I welcome most of this section and in particular the mention of Neighbourhood Plans which Noted. It is the intention of the council to fully despite their potential importance are for some reason NOT mentioned in the Forward. From support the production and outcomes of the words used to describe their function and importance I need a little bit more convincing that Neighbourhood plans, however it should be noted the Wiltshire Council really are intent on encouraging their development. Also that they are that Neighbourhood plans will need to be in determined to take full account of the aspirations which will be expressed in them. In other general conformity with government guidance. 130 words Neighbourhood Plans will have a value and will be able to influence future development. Chapter 1. Q22 Through the Core Strategy we are attempting to I do not support what I see as the politically correct objectives of "reducing disadvantage and cut greenhouse gas emissions through ensuring inequalities, and tackling the causes and effects of climate change". There may be some development is located in the most sustainable disadvantages which need correction but there is simply no way that the people of Wiltshire can location and ensuring that new buildings are built on their own address the causes and effects of climate change. We can play our part in to energy efficient standards. attempts to mitigate the causes but that is all. Cross Comment No. Comments Officer Comments Issue Reference By The strategy for Malmesbury recognises the Given the historical importance of Malmesbury may I suggest that this needs to be given more important historic context and assets, and the emphasis. Other than this I am content with the various paragraphs except that in Para 2.16 I importance of the conservation area. Core policy should like to see mention of persuading developers to include rainwater collection facilities Built 38 – ensuring protection of the historic 133 either per house or per collection of houses or industrial units for uses such as the flushing of SO6SO2 environmentW Malmesbury environment also ensures the historic toilets and washing. We simply must start to do this increasingly to reduce the pumping of ater environment is taken into account.Consideration water from our rivers and underground reservoirs and to reduce the potential for the water table will be given to utilising rainwater through the to be progressively lowered. development of the water resources policy. Inappropriate development could be that which As an aspiration I have no objections to the Spatial Vision but many of the objectives are produces many motor car trips in a remote subjective. For example what is inappropriate development ? And how is maintaining the location or one that has very poor design and "vitality and viability of town centres" to be described for development purposes ? Also could harm its setting. There are many examples promoting sustainable forms of transport is something which has been exercising minds for and each case will be treated on its merits. 135 many many years. It needs to be given a much higher priority with alternative schemes being Viability and vitality will be established through Chapter 3. Q22 piloted. Here in Malmesbury we are still having to put up with totally unsuitable Andy Buses monitoring and for example number of empty negotiating their way with great difficulty around the centre of town and running for the most shop units, value of investment and customer part almost empty. They are not tempting people to leave their cars at home and cannot be an feedback. The strategy will facilitate innovative efficient way of using council tax payers money. transport solutions and promotes increased choice. Strategic objective 5: to protect and enhance the natural environment States that "where possible, development will be directed away from our most sensitive and valuable natural This is further clarified in the section on 138 assets, towards less sensitive locations." This statement is not clear enough - the "most Biodiversity and Geodiversity on page 190 of the Chapter 3. Q22 sensitive and valuable natural assets" should be defined - I presume they include AONBs for Core Strategy. example? Dear Sir/ Madam, The Valley Parishes Alliance have reviewed the above plan and are encouraged by its content, in particular the commitment to “protect and enhance the River Avon corridor”. We are, however, disappointed with the lack of consideration of strategic plans in neighbouring counties and, in particular, strongly urge you to cross-reference with the long-term strategy of Bath & North East Somerset. It is essential coordination takes place on cross-border Noted. The Council has a duty to work movements of commuters and businesses and the related impact on the transport collaboratively with neighbouring authorities and infrastructure. Other areas of overlap include the need for a coordinated strategy on reducing have regard for their plans. Wiltshire and BANES the traffic congestion in Bath and Bradford-on-Avon and for managing the many stakeholder Neighbouring have continued to work together over issues 171 interests on the Kennet & Avon canal. The VPA would be happy to work with you on these Authority Q22 particularly around commuting and transport issues. Specifically we would also like to draw your attention to the cross-border communities of DPDs during the formation of the Core Strategy. Limpley Stoke (Wiltshire) and Freshford (B&NES) which work extremely close together on a Nevertheless, help from community organisations number of projects (including affordable housing) to the benefit of their combined and socially will strengthen cross-border planning. inter-connected communities, but are hampered currently by the poor coordination between the respective county departments. The Valley Parishes Alliance (VPA) is a cross-county border alliance of nine Parish Councils (six in B&NES and three in Wiltshire) along the River Avon valley, East of Bath and represents the interests of some 11,000 residents. With best wishes Simon Coombe Chairman Valley Parishes Alliance

2.13 Deprivation. This paragraph focuses too much on rural deprivation and isolation from The deprivation data is taken from the essential services and fails to adequately recognise that the most deprived communities in Department for Communities and Local Wiltshire are often well located for local services in urban centres (Salisbury and Trowbridge). Government Indices of Deprivation. Both the 187 Chapter 2. Q22 Other issues which lead to deprivation need to be recognised and addressed in the Core urban and rural aspects of deprivation have been Strategy. The focus on regeneration and growth in the Principal Settlements, with increased considered and policies formulated to address emphasis of economic growth should in part address these issues. these.

3.2 Strategic Objective 1. This statement would read better as: to minimise the risk of flooding 188 noted Chapter 3. Q22 and ensure effective water management. Cross Comment No. Comments Officer Comments Issue Reference By

Further consultation will be undertaken for the Core Policy 35 - Green Infrastructure. This policy, if it is going to refer to specific sites at all submission draft of the core strategy. The 196 should include Trowbridge; Paxcroft Brook through Paxcroft Mead, Biss Meadows, Links to Biss consultation document includes measures to Trowbridge Woods, Kennet and Avon Canal etc. promote sustainable forms of transport (SO8) and provide adequate infrastructure provision (CP3).

6.8.3 This section needs to include reference to the phasing of delivery of large sites including clear policies to secure pedestrian and cycle routes to significant locations, particulalry including town centres as part of the first phase of any development. (The mistake made with the pahsing All strategic sites will be required to develop a of Paxcroft Mead must not be repeated.) Core Policy 46 Demand Management . Bullet 4 . The master plan which should include phasing strategy and policies need to be flexible in managing publicly available private non-residential 197 requirements where necessary. The strategy also SO3 parking, in particular in referring to the implementation of parking restrictions and charges includes policies which seek to promote consistent with those of council run car parks in the local area. This needs to be done on a sustainable forms of transport. settlement by settlement basis, depending on local factors so as not to unfairly give an advantage to existing operators above those seeking to invest in new developments, so that all existing car-parks are considered, not just council run car parks.

Thank you for the opportunity to comment on this document. Action for the River Kennet (ARK) have the following comments: We welcome Wiltshire’s commitment “ to protect and enhance Topic Paper the natural environment”. Topic paper No.5 and Strategic Objectives SO 5 and SO 10 do not 5; legislative deal robustly with the problems of over abstraction in the upper Kennet and ARK recommends context – these should be strengthened to say: “the problem of over-licensing and over-abstraction of the The Water Water Kennet has yet to be solved, and pressure needs to be maintained on Thames Water and the Framework The comments are noted. Additional emphasis resources; Government to agree on the funding necessary to access other sources of water to meet Directive; on the existing issues associated with water abstraction 231 Swindon’s demand.” The Water Framework Directive and its requirements are not given Catchment abstraction in the River Kennet will be added to issues SO10 sufficient priority. ARK recommends that that the European Water Framework Directive be Flood Topic Paper 5 to increase overall awareness of (focused on listed as part of the legislative framework in the Topic papers. ARK recommends greater Management the water resource matters. the River emphasis should be given to the value of rivers (particularly the Kennet) as natural green Plan; River Kennet). corridors. In general ARK would strongly endorse the overall approach proposed in the Basin Conclusions that “sustainable development in Wiltshire must be encouraged in a responsible Management manner which respects the importance and fragility of our natural environment”, and “that all Plan. stages of decision making are informed by relevant ecological information”. Cross Comment No. Comments Officer Comments Issue Reference By The options evaluated in the interim Sustainability Appraisal in relation to Core Policy 48 - Strategic Transport Network - provide an example of the poor quality of the options which have been considered. The details of the options have not been clearly specified in the evidence base provided, however further enquiries have revealed that the ‘Option 2' - termed the ‘Status Quo' option - being evaluated for this Core Policy contains schemes from the Wiltshire Structure Plan 216 (according to an email from Ashley Hewitt, Wiltshire Council Complaints and Freedom of Information Officer dated 2.8.211). The schemes included in this option have in many cases already been further evaluated and abandoned. For example: A33 Stonehenge (to include the Winterbourne Stoke Bypass and flyover at Countess roundabout). - cancelled in December 27 due to escalating costs A35 Westbury bypass - following a public inquiry in 28 the Inspector recommended that planning permission be refused and the Government agreed with that decision. Salisbury: Harnham Relief road and Brunel Link - following two planning applications in 22 and 25, both withdrawn, Wiltshire Council's delegated decision ref: HT-3-1 taken 15/1/1 - see https://cms.wiltshire.gov.uk/ieDecisionDetails.aspx?ID=247 - removed these Comments noted. The Core Strategy seeks to schemes from the list of schemes to be supported and protected in local plans, with the reason increase the self-containment of towns and for the removal of both being given as ' Scheme unlikely to be funded and not supported locally' villages in Wiltshire to provide the opportunity for The Sustainability Appraisal is, we are told, supposed to define and consider 'reasonable use of sustainable transport measures to be used alternatives' [See S.A. section 2.3]. To take a ‘status quo' option which is based on an and the core policies on transport encourage the assemblage of historical and outdated schemes cannot be considered an investigation of a use of modes of transport other than the private reasonable alternative. Rather than alternative options which involve road building the Core car.Core policy 48 also promotes the rail and bus Strategy should be focusing on stronger policies to give real alternatives to the use of the networks in Wiltshire and the Council is currently 232 private car. There should be a recognition that an increasing percentage of the county's SO8 TransportRail SO8 developing a bid to the Department for population is living in urban areas and that walking/cycling and public transport links - both bus Transport's Local Sustainable Transport Fund to and train - can and should become real options for an increasing proportion of the county's improve rail services and accessibility to rail residents. It is relevant to note that the Options Assessment Report [OAR] produced by Atkins stations between Salisbury/Westbury and as part of the Salisbury Transport Strategy (Jan 21), which was presented to the Inspector as Swindon.Core policy 48 only includes the railway part of the Examination in Public of the South Wiltshire Core Strategy concluded that a ‘Radical stations where there is evidence that it is realistic Option' would best enable Salisbury to meet the challenges of addressing future growth in and viable for the railway stations to be travel demand in a sustainable manner. (STS OAR para 7.13). This approach needs to be developed or improved during the plan period. reflected in the transport strategy and policies to be adopted in the county wide Core Strategy. Core Policy 48 places too much emphasis on the ‘selective improvement' of the A35 corridor and insufficient consideration is given to the development of bus and rail links in Wiltshire. The intention to develop and/or improve Corsham, Melksham and Wootton Bassett rail stationsis welcome, however this aspiration falls far short of the vision which Wiltshire expressed in its first Local Transport Plan 21/2-25/6. At that time there were aspirations for priority new stations at Corsham, Wootton Bassett and Wilton as well as for possible new stations at Minety, Purton, Moredon, Lacock, Holt, Staverton, White Horse, Codford, Wylye, Dinton, Porton and Alderbury (see WCC LTP1 Figure 3.6.6). Both Porton and Wilton stations were supported in policy T12 of the Wiltshire Structure Plan 216 and there is no explanation why these are no longer included in the list of stations for development. There is a strong case to be made for stations at both these locations because of the support in the South Wiltshire Core Strategy for the Porton Down employment site and the developments which are proposed around Wilton (UKLF and Fugglestone Red). Cross Comment No. Comments Officer Comments Issue Reference By Over the period 1978 to 23, some 25,367 new dwellings were built in North and West Wilts. The 1996 to 216 Swindon and Wiltshire Structure Plan continued the trend, with 2,75 dwellings for the West Wilts and North Wilts districts. The Wiltshire Core Strategy proposes to hot-house the Western Wiltshire area again with well over 2, new dwellings for the plan period distributed over a number of towns. We question fundamentally whether this development-led and distributed model of expansion in an area which is ill-equipped for the purpose, can work in terms of transportation. The model proposed has already brought many of the traffic problems of the south east to Wiltshire, with increasing congestion, rat-running and communities small and large seeing traffic on the rise. We do believe that the stated idea of ' Providing for the most Noted. Housing numbers in the consultation sustainable pattern of development that minimises the need to travel and maximises the document have been reduced from the previous potential to use sustainable transport' will work - this is far too simplistic, unfortunately. RSS targets. Transport modelling has been 239 Surrounding local authorities have reduced numbers compared to the RSS but Wiltshire has Chapter 1. Q22 undertaken to ensure there is capacity on our not done so except for in South Wiltshire. North East Somerset Council for example, faced a transport system to accommodate additional target of building more than 21, homes by 226 under the last government. The council's new growth. plan is to build 11,. It is unclear why should Western Wiltshire take the development that Bath and others will not have. The number of AQMAs is increasing in Wiltshire generally. In Wiltshire Council's 211 Air Quality Progress Report it is apparent that many towns are now suffering over the safe limit of nitrogen dioxide, Table 2.3a Results of Automatic Monitoring for Nitrogen Dioxide: Comparison with Annual Mean Objective shows that Bradford on Avon reaches nearly two times the safe limit with Calne, with Chippenham, Devizes, Salisbury, Marlborough and Westbury all exceeding safe levels. Just on this basis alone, and considering that much new growth is already allocated, we do question whether the level of growth proposed is sustainable. The commuting data is taken from the 2001 Census. This clearly shows that many more The statement: ' Wiltshire is a desirable place to live and, as the high level of out commuting people commute from Wiltshire than to Wiltshire. shows...' is not backed up by evidence. It is unclear what is meant by 'out-commuting', and why The aspiration of the strategy is to ensure that commuting over the border to Somerset for example if you live in Warminster or Westbury, is a sufficient employment opportunities are provided bad thing. In-commuting is not dealt with - Trowbridge for example has more in-commuting in each locality for the resident workforce. Some 240 than out-commuting according to regional statistics. What we need is data on commuter flows Chapter 2. Q22 cross border flows are sustainable where they and a proper transport model for Western Wiltshire to better understand the situation. Much use public transport or are over very short more analysis is needed regarding demand for travel and its match with public transport distances, but by providing suitable employment provision along the main commuting corridors, as is the stated policy in the Wiltshire in the place of residence, it provides further Community Plan. choice for residents and allows for these flows to be minimised.

I am writing with concern about the inclusion of Hilperton in to the Town of Trowbridge Map 5.5. Hilperton is a separate village and has its own identity, this has been the case for many years and Hilperton has its own PCC. The identity of the "village" is very important to the residents and the rural areas surrounding Hilperton and in deed many areas of Wiltshire are fast diminishing. The Hilperton gap in particular is a vital and well used rural area, it not only Hilperton should be identified as a separate 'large 241 contains much wildlife and many hedgerows but it allows all residents to enjoy the countryside CP7 village' and this will be corrected in the General Trowbridge in the village. Hilperton should remain as a separate village with current "green" areas Submission Version of WCS. remaining as rural for the community. Hilperton should be treated in the same way as the other surrounding villages of Trowbridge and remain as villages rather than being incorporated in to one huge area, resulting in loss of identity for all areas. Hilperton has its own village design statement which was fully approved and agreed by Wiltshire Council- this must not be forgotten. Cross Comment No. Comments Officer Comments Issue Reference By If it is impossible to achieve am complete solution, does that mean one should not strive for improvement? The Strategy seeks to significantly On Climate Change: the concept of self containment of the main settlements and a reduction in improve the self-containment of our settlements, it the need to travel is a laudable but unachieveable objective in view of modern day travel does not claim to be a panacea, but it is a patterns. There is too much reliiance on it. A clear committment to reduce the transport-related tangible way in which we can make a meaningful carbon emissions by the provision of alternatives to the car needs to be included in the carbon effort to address a major cause of motor vehicle Objective. Whilst supporting Objective 8 in terms of sustainable modes, we are less keen on: ' trips in Wiltshire, which is through out commuting. Measures will have been implemented which reduce traffic delays and disruption, and improve Strategic transport corridors are main arteries journey time reliability on key routes ' as it is well establighed that people travel more faster they 245 shown on the Area Maps and the plan will not Chapter 3. Q22 can go. In other words, congestion is a major restraint measure when it comes to too much and allow development that could prejudice the too far travel by car. The faster people can travel, the more they do so. When it comes to the reliability of these routes and major development statement: ' Strategic transport corridors within Wiltshire will have been safeguarded and, will need to show how its impacts can be where appropriate, improved in a sustainable way ' we are lost to see exactly what this means. mitigated. The Council is resourced to deliver this Which transport corridors are we referrring to here? Rail seems not to be in the picture. strategy. Yes impact the Core strategy has been However increasingly the government expects local authorties to push for their rail needs, and produced in liaison with Natural England and the to take more control. Environment Agency. The Strategy will facilitate improved rail use, but has to be realistic over current funding. Comments noted. Every effort is made to ensure General comment: If you really wish to get local people to comment meaningfully on your Core the document readable and understandable to all. Consultation 258 Strategy, you will have to make it much easier for them to support/object specific points. The It is also necessary to ensure that the document Q22 process present document is a masterpiece of obscurity. is detailed enough to withstand scrutiny and be considered sound. From Swallowcliffe Parish Council 1. Thank you for the opportunity to comment on the proposed policy, which has been considered in detail. There is much that is good here, but the document is complex and far from being readily accessible: the relegation of work already done on the S Wiltshire Strategy to electronic cross reference adds to this and is unhelpful. 2. As the Parish Council for a very typical small village, we have concentrated upon areas where we have valid competence to offer, particularly on those matters impinging directly upon small villages. We have particular concerns in this context, which are covered below and in commentary elsewhere in this document. 3. Matters of Principle . That said, there are certain concerns of principle: Strategic Objectives . This is supposed to be a strategic document, yet there are no less than 10 strategic objectives. As the Foreword observes, there are difficult conflicts of interest to resolve: a good strategy focuses upon a few clearly identified strategic objectives to make this process easier. A more rigorous approach indicates that some of the 10 proposed Thank you, we endeavour to make all documents objectives might be combined into a single objective covering like areas: for example, 2, 8 and as clear as possible. We will take note of this and 10 have much in common; Local Relevance . This is supposed to be a document about our see what improvements can be made. The South 276 County, Wiltshire, yet some of the objectives and proposals are dangerously general and oddly Wiltshire Strategy is being incorporated without Chapter 3. Q22 weighted. For example, climate change cannot be resolved by Wiltshire alone, it is a national any fundamental changes. Comment noted and issue to which Wiltshire can only make a contribution; and, the aspiration to relieve housing the number of Strategic objectives will be inequalities seem vague and dependent upon economic factors far beyond the influence of the rationalised in the next version. Agreed County. The risk is that the position of these issues in this list of objectives is in danger of skewing the argument for resources, prejudicing those areas of greater importance to the people of Wiltshire, and which can be resolved more easily. Infrastructure . The general approach to infrastructure in the document is disappointing, possibly due in part to the weighting of the strategic objectives on offer. Infrastructure, most especially electronic infrastructure, is fundamental to economic growth and the provision of services in rural areas. Furthermore, empirical evidence nationally indicates that growth and development tends to follow strategic infrastructure initiatives. Infrastructure development is a headline matter, yet in these proposals the best parts are lost for the most part in the technical details, obscuring issues of importance. For example, the pious objective of sustainable transport deflects attention from the continuing reality of the importance of movement in a rural economy in the Cross Comment No. Comments Officer Comments Issue Reference By context of a growing global economy - this means addressing road capacity Neighbourhood Plans. Finally, the emergence of Neighbourhood Plans is underplayed - they are tucked away at present and their omission from the Foreword is perhaps surprising. We suspect that were more weight given to their importance, some of our concerns on the approach to small villages might be allayed 4. Small Villages. The proposed Settlement Strategy gives us real cause for concern: it conveys an uneasy impression that in Small Villages nothing will be allowed to change. Moreover, contradictions are apparent between this and the aspirations for the preservation of services, for example, Public Houses. The specific planning restrictions offered would seem to exclude exactly the sort of minor development which may make or break the viability of a small community. Whilst acknowledging that Wiltshire is fortunate to have a large number of historic and beautiful small villages, there must be the capacity for sensible development to ensure their continuing vibrancy as communities. The capacity to allow for this should be firmly locked into the strategy with prominence given to the engagement of local communities in the process. Graham A Ewer Chairman

From Swallowcliffe Parish Council Our general comments have been submitted in response to 277 Noted Q22 the Foreword Graham A Ewer Chairman By Swallowcliffe Parish Council Map 2.2 It would be helpful to identify the Community Areas if 278 Noted Q22 possible Graham A Ewer Chairman By Swallowcliffe Parish Council This is supposed to be a strategic document, yet there are no less than 10 strategic objectives. As the Foreword observes, there are difficult conflicts of interest to resolve: a good strategy focuses upon a few clearly identified strategic objectives to make this process easier. A more rigorous approach indicates that some of the 10 proposed objectives might be better combined into a single objective covering like areas: for example, 2, Thank you. Comment noted and the number of 8 and 10 have much in common. The number of objectives here leads to an element of Strategic objectives will be rationalised in the next distracting bathos, with flooding seemingly tacked on as an afterthought and overshadowed by version. Agreed. The order of Strategic 279 climate change. In reality it is all part of the same issue. Furthermore, this is supposed to be a Objectives within the document is not a prioritised Chapter 3. Q22 document about our County, Wiltshire, yet some of the objectives and proposals are and no added weight should be assumed through dangerously general and oddly weighted. For example, climate change cannot be resolved by theory ordering. The strategy is deliberately Wiltshire alone, it is a national issue to which Wiltshire can make a contribution. Yet its position economy led. in this list of objectives is in danger of skewing the argument for resources prejudicing those areas of greater importance to the people actually living in Wiltshire, and which can be resolved more easily. Of course, climate change is important, but realistically in the foreseeable future, employment and services are higher on the agenda for the majority. Graham A Ewer Chairman

I presume that in section 1.11, Village Design Statements are intended to be included under Noted. VDS's that have been adopted will still 291 bullet point 3 (community area plans and parish plans) and will continue to have their extant Chapter 1. Q22 maintain their status as SPD. recognition as Supplementary Planning documents. Cross Comment No. Comments Officer Comments Issue Reference By Thank you for this opportunity to respond to this informal consultation on the draft Core Strategy for Wiltshire. Detailed comments will be made at a later point in time by Wiltshire FRS for inclusion in the evidence base for the final version of the strategy and for inclusion in the Infrastructure Delivery Plan. However, I now make the following, general comments on the Draft Core Strategy on behalf of Wiltshire Fire and Rescue Service. 1. Funding for Wiltshire FRS Infrastructure Requirements Wiltshire FRS does not receive central government funding for the capital costs of infrastructure requirements related to this growth. Whilst the FRA seeks to optimise the management of its existing infrastructure, in the absence of central or local government funding for capital infrastructure it must rely on local funding through developer contributions section 106 (Town and Country Planning Act) or CIL, when adopted. Funding and support will be needed on three levels: Critical infrastructure will be needed to allow each development to take place in the form of suitable fire fighting water mains and fire hydrants. These will need to be provided at the cost of the developer. Funding will be sought for the additional FRS Technical Fire Safety capacity that will be needed to manage the additional development control work created by the new developments. Additional funding will be needed to provide essential infrastructure such as new, upgraded or relocated fire stations, vehicles or equipment. There may be opportunities for co-location with other service providers, such as Comments from WFRS noted. Support for and other emergency services. Support will be sought for the place shaping role of community fire 299 involvement in the infrastructure planning process Question 3 stations across Wiltshire. 2. Increased community risk to be managed by Wiltshire FRS The appreciated. growth proposals within the draft core strategy will increase the risk profile that must be managed by Wiltshire FRS. This increased risk will be present during the construction phase and further risk will also be present upon occupation of the new buildings. The growth affecting the strategic settlements, market towns and local service centres will require changes to the existing infrastructure that has been provided based on previous risk profiles. Wiltshire Fire and Rescue Service is currently assessing its additional or amended essential infrastructure requirements due to the growth across these settlements. Notably, the comments in the strategy that development may take place on sites adjacent to settlement boundaries may require relocation of existing FRS infrastructure to manage the new locus of risk. Additional infrastructure will be required to manage the additional risks posed by development in the smaller settlements and villages across Wiltshire. The new employment land and certain housing development will impose additional workloads during the development control process on the Wiltshire FRS Technical Fire Safety team. Should there be increased traffic density levels due to the growth; these could impact on our performance by increasing the number of transport-related incidents attended and also by increasing our response times to incidents. Additional infrastructure may be required to maintain current performance levels given the increased risk. Cross Comment No. Comments Officer Comments Issue Reference By

Topic paper 17 paper sets out the progress made in determining an appropriate requirement and distribution of housing for Wiltshire from 2006 to 2026 to inform the draft Wiltshire Core Strategy. This process considers the strategic objectives for The town should not be allowed to grow beyond a point where the infrastucture can no longer the county as well as taking into account local suport it. The schools and the utilities are stretched enough. There needs to be an assesment factors and aspirations for growth identified of what the town needs, is it affordable housing for young families or is it more smaller units for through community consultation. older people or does it actually need anything extra. Until this is Housing type is addressed in core policy 29 - addressed development should be on hold. There is also a need to preserve the town for it's SO3, CP2, meeting housing needs and will use up to date heretige and history if the town becomes over large with more estates created on the edge then Housing 325 CP39 evidence such as the Strategic Housing Needs Malmesbury it will lose it's culture and become an anonymous collection of houses lacking in comunity and Design SO6, CP37 Assessment and other local evidence to the things that make Malmesbury special. We accept that Wiltshire needs more houses but not determine housing type. enough consideration has been given to what type of housing, where is it best placed and at Core policy 37 sets criteria to ensure new what overall cost. May we also suggest we take a leave from French planning and any new development is of high quality design and it is houses are built on a ratio of land to internal space to prevent builders piling three story 4 bed recognised as a key issue in Malmesbury. family houses with living space and gardens not big enough to swing the proverbial cat! Small sites will be allocated through either the community led neighbourhood planning process or another planning mechanism in close consultation with the local community.

Overall we support the sustainability, environment and climate change objectives in the Core Strategy. While appreciating these need to be balanced against other objectives such as economic growth, it is vital that these objectives are taken seriously and are not just worthy Agreed the Strategy is part of a wider process aims that fail to actually influence development in practice. Wiltshire Council is improving in and must lead to tangible outcomes on the 335 Chapter 3. Q22 these areas, for instance by finally starting to take recycling seriously, but it still lags ground. It is designed to be realistic, achievable considerably behind other counties in key sustainability areas such as public transport and and deliverable. renewable energy. We have specific comments on the Chippenham and Corsham Community Area Strategies. [see comments 336 and 337]

CONSULTATION ON EMERGING WILTSHIRE CORE STRATEGY DEVELOPMENT PLAN DOCUMENT The Health and Safety Executive (HSE) does not comment on individual Local Development Plans. Local planning authorities are required by: • Regulation 20 of the Town and Country Planning (Development Plan) (England) Regulations 1999* to have regard to the objectives of Article 12.1 of the Seveso 11 Directive in formulating their general policies in Part 1 of a unitary development plan. These objectives are: • to prevent major accidents and limit the consequences of such accidents for man and the environment; • the need; i. in the long term, to maintain appropriate distances between establishments and residential areas, areas of public use and areas of particular sensitivity or interest; and ii. in the case of existing establishments, for additional technical measures in accordance with Article 5 of the Directive so as not to Health and 352 increase the risks to people. The HSE extranet system, to which all planning authorities have Noted. Q22 Safety access, contains lists of all major hazard sites and major hazard pipelines, along with consultation zone maps where available. This information, in conjunction with "PADHI - HSE's Land Use Planning Methodology", which is available on the HSE website ( http://www.hse.gov.uk/landuseplanning/padhLpdf ), will allow you to identify incompatible developments within each consultation zone. If there are any major hazard sites and pipelines, or associated consultation zones, within the Local Development Plan area, it would be helpful to indicate to potential developers the constraints likely to be imposed by their presence. The paragraphs in the attached annex could form the basis of a policy statement for inclusion in the plan, which may subsequently avoid the submission of planning applications containing inappropriate proposals. In addition, we suggest that the proposal maps be marked to show the Cross Comment No. Comments Officer Comments Issue Reference By location of any major hazard sites. We particularly recommend marking the routes of any major hazard pipelines as, in our experience, most incidents involving damage to buried pipelines occur because third parties are not aware of their presence HSE will advise you should there be any changes in how HSE provides land use planning advice as a result of recommendations on the integration of societal risk into the planning system around major hazard sites made by the Major Incident Investigation Board into the fire and explosions at the Buncefield 011 Storage Depot, HSE's proposals for revised policies to address societal risk around onshore non-nuclear major hazard installations, or other developments in the planning sphere.

We are concerned that Hilperton village is not adequately protected. We cannot understand This matter is addressed in response to ID 241 364 why it is not clearly recognised as a Large Village. This would preserve the character and CP7 General Trowbridge above. identity of Hilperton and prevent it becoming swallowed up into Greater Trowbridge.

The main points from my perspective are: Topic paper No.5 and Strategic Objectives SO 5 and SO 10 do not deal robustly with the problems of over abstraction in the upper Kennet and I Topic Paper recommend these should be strengthened to say: "the problem of over-licensing and over- 5; legislative abstraction of the Kennet has yet to be solved, and pressure needs to be maintained on context – Thames Water and the Government to agree on the funding necessary to access other sources The Water Water of water to meet Swindon's demand." The Water Framework Directive and its requirements Framework The comments are noted. Additional emphasis resources; are not given sufficient priority. I recommend that that the European Water Framework Directive Directive; on the existing issues associated with water abstraction 368 be listed as part of the legislative framework in the Topic papers and that Wiltshire Council Catchment abstraction in the River Kennet will be added to issues SO10 gives a commitment to play an active role in delivering the Catchment Plan for the Kennet. I Flood Topic Paper 5 to increase overall awareness of (focused on recommend greater emphasis should be given to the value of rivers (particularly the Kennet) as Management the water resource matters. the River natural green corridors. I welcomes measures to promote sustainable urban drainage systems Plan; River Kennet). In general I would strongly endorse the overall approach proposed in the Conclusions that Basin "sustainable development in Wiltshire must be encouraged in a responsible manner which Management respects the importance and fragility of our natural environment", and "that all stages of Plan. decision making are informed by relevant ecological information".

389 Support 1.5 Vision for stronger , more resilient communities Support noted. Chapter 1. Q22 390 Support para 2.17 Wiltshire Council will address this omission. Chapter 2. Q22 Support strategic objectives para 3.5 with partic support of strategic objective 2, and following key outcomes: Strategic objective3, bullet point 3: delivery of more modest growth proprtionate 391 to size in smaller settlements bullet point 6; efficient use of land bullet point 8: range of housing Support noted and welcomed. Chapter 3. Q22 types & sizes bullet point10: necessary infrastructure provided. Strategic objective 4 bullet point 7: key local facilities. Cross Comment No. Comments Officer Comments Issue Reference By Affordable Housing Core Policy 28 The government has recently launched the ‘affordable rent' product which will replace ‘social rent' in many instances. This national policy is in its infancy and we are yet to see it work in practice. It is market driven being that it is linked to 8% of open market rents. Given that there are varying markets across Wiltshire the proposed requirement for 4% affordable housing will be acceptable in the medium to high value areas. However we question the viability in the lower value areas, given the reduction of grant and in particular the requirement for nil public subsidy for affordable housing delivered by way of Section 16 Agreements. We would therefore suggest the policy provides flexibility , so either there are individual affordable housing policy thresholds per area which could be linked to community areas and/or there is a mechanism for reduction if a site's viability is in question, this is especially the case for sites which require expensive infrastructure. We welcome the council's inclusion of a specific target of 11, new affordable homes over the plan period. However, it should be noted that the soon to be published SHMA, states there is an annual net need of 3,68 dwellings, policies need to be included to facilitate this. Exception Sites The policy should be altered to ensure that ‘exception sites' can be carried out on other settlements (those not defined as large and small villages) as this is critical for the delivery of affordable housing in rural areas. Following the comprehensive spending review last year, there is a significant reduction in grant therefore the policy needs to allow flexibility on rural exception sites so we have the ability to use cross subsidy from private sale units. Viability assessments and an open book methodology could form part of the policy. In relation to the qualifying criteria we support 5 out of the 6 points, however criteria (v) requires that ‘the site is accessible to employment and Comments regarding affordable housing noted. services' the problem is that this is capable of interpretation in many ways. We are concerned Viability will be taken into account in both that, given some of the Council's other proposed policies it could be used to preclude determining the appropriate threshold and in its development in many villages. We would suggest that this is removed from the Policy as it is 408 subsequent application. More detail will be SO3 also inconsistent with other statements in the document. Meeting Housing Needs Core Policy provided within detailed guidance as necessary. 29 We strongly support the proposed policy on meeting housing, in particular the section on Comments regarding ‘vulnerable and older meeting the needs of vulnerable and older people. The level of household growth in Wiltshire people noted’. from the 65 + age group over the plan period justifies a positive policy towards the delivery of older person care and accommodation. The existing stock is simply unprepared for this level of growth. A specific policy to increase delivery of these types of development will help to increase choice and opportunity for older people in later life. Whilst many older people will choose to stay in their homes others will have to move and the provision of further older person care and accommodation will allow this. This in turn will free up under occupied homes for young families. We are pleased to note that Extra Care schemes outside but adjacent to defined boundaries will be considered appropriate if clear evidence can be provided. However it would be helpful to provide a definition of an ‘exceptional circumstance'. We do not understand why this policy only applies to Extra Care schemes and not the full range of options. All of these types of development suffer from the same problem with competing with general markets schemes for sites in the built-up area and require some assistance to be brought forward. We strongly recommend that this policy is amended to allow the full range of older person care and accommodation is permitted in these locations, providing a need can be demonstrated. We would also encourage the Council to consider the allocation of specific sites in later planning documents to further aid the delivery of these schemes. Lifetime Homes Standards Core Policy 3 We consider the policy requirement of Lifetime Homes across all homes to be dictatorial. Taking into consideration current market conditions this approach may hinder development due to the extra construction costs required to carry it out. Our preference would be for a percentage of homes to be provided per site to meet wheelchair standards, such as the Habinteg standard. Cross Comment No. Comments Officer Comments Issue Reference By The proposed core policy on sustainable Sustainable Construction and Low Carbon Energy Core Policy 26 There is a fine balance construction and low carbon energy includes the between the quality of developments and quantity. As an organisation we support sustainable statement that "In all cases the council will have development but we take a pragmatic view. We consider the proposal for Code for Sustainable regard to the impact of these requirements on the Homes Level 4 from 213, Level 5 from 216 and zero carbon standards on developments over 5 409 viability of development will be taken into Viability SO2 units from 213 could stifle development and the delivery of affordable homes, given the current consideration". The policy is therefore considered economic climate. It is useful to note that the Homes and Communities Agency have relaxed to include sufficient flexibility to ensure that it will their requirement for compliance with the higher levels of sustainable code due to the economic not prevent the delivery of appropriate climate. development. I would like to object to the current proposals for the development of Chippenham town centre until 2026. Chippenham is a rural market town which has a unique character of its own. The surrounding countryside includes outlying villages with their own histories and unique character which will be lost with the proposed developments. There is currently pressure on the infrastructure of the town, for example traffic in and out of Monkton Park and traffic congestion around the Bridge Centre. The proposed development would add to the current problem. Increasing the housing would further add to the congestion. To overcome this more roads will be built, possible by-pass to the north of the town would destroy the countryside and put a further strain on the current infrastructure. The infrastructure would need to be expanded with the current proposals which would further add to the proble; in effect a domino effect. The proposed plans would be detrimental to the town for the following reasons:- Under the former RSS proposals there is no longer an imposed requirement for new homes, so why is the Council keen on pushing this through; apart from financial gain. The main aim of the council Comments noted. Details of site selection and should be protect the town’s heritage and the surrounding countryside for the residents of the analysis of sites is set out in Topic Paper 14. This town. Developers will come and go, but it is the residents who will live with the consequences. has included taking into account the additional This view is shared by hundreds or Chippenham residents that have been surveyed, our MP, consultation work for Chippenham. The evidence it’s echoed by environmental NGOs such as North Wilts Friends of the Earth. Many of the now presented provide best solutions to arguments are supported by the Local Area Board’s own publications and stated in Wiltshire accommodate sustainable development at the Council’s own Core Strategy Sustainability Appraisal. If the development went ahead for the town in light of the emphasis on the delivery of Northern and Eastern developments and the new South West development at Showell, this employment land to develop the strategic would put an increased reliance of the car to link the towns population with the A350 and the employment role of Chippenham and the London and Bath roads. Further roads would need to be constructed to accommodate the Housing 412 proposed reduction in the overall number of Chippenham congestion further destroying the countryside. If the roads were built, there would be no Requirement homes to be provided during the plan period. The stopping the developers developing the new areas surrounding the newly built roads, further Regional Spatial Strategy identified levels of destroying the character of Chippenham town and the countryside. During rush the A350 is housing and job growth for areas such as regularly at a standstill, further development would add to this problem, and there are no plans Wiltshire. The abolition of the RSS has not to widen the A350 to accommodate resultant increase in traffic. More homes would result in removed any obligation to large-scale more people adding pressure on the current transport systems; more cars and an increase to development. Rather it is necessary for the level the currently overcrowded trains. Commuters regularly have to stand going to and coming back of housing and job growth to be determined from London; there are no plans to improve the rail links to London. The growth in the locally within Wiltshire. This is explained in the population of Chippenham would be detrimental to employment as most of the increased Core Strategy. population would not find employment in Chippenham, as most new employers would rather be located in Swindon and Bristol. As the public services in Chippenham are under pressure, a significant increase in the towns population would impose an increased strain on these amenities which are vital to the town such as leisure facilities, libraries police, medical, maternity and dental services. The planned proposals would have a detrimental effect on the surrounding countryside. The area to the North of the town is currently enjoyed by residents and non residents. It is a place of natural beauty enjoyed by many people. People walk their dogs in this area, children play in this area. There is very little amenities for the older child / teenager. Yes there are playgrounds for children, but these only cater for children up to a certain age. This area supplies a place where the older child can meet friends and enjoy the countryside. If this was taken away by the proposed development, the only place would be the town centre. The area is also used by schools for nature studies and other organisations such as the Scouts and Guides. It is stated that Birds Marsh Wood, would be protected from the Cross Comment No. Comments Officer Comments Issue Reference By development. How are you going to do this? The land in front of Birds Marsh is planned for a by-pass, this alone would destroy the area with noise and pollution. The land is used by several species of deer, badgers, buzzards and other birds of prey. The building of a road even with a buffer zone as proposed would drive the wildlife away. It would be impossible to protect the flora and fauna of the area. A prime example of this is Vincients Wood in Chippenham. This wood teamed with life, now it is devoid of life due to the housing development and the nearby A350. This is now a dead wood. Progressing the development would have the same effect on Birds Marsh Wood Finally developers and apparently the council are not worried what happens to Chippenham Town. The only driving force in this matter is financial gain. Once these Greenfield sites have gone, they are gone for ever and cannot be brought back. Please listen to the residents of Chippenham and act accordingly. It is not just a matter of ticking a box to say we have consulted the residents and proceed regardless of public feeling. This is a town that people enjoy and are proud of. Implementing these proposals would destroy a rural town full of character and beautiful surrounding countryside. David McCarthy Hill Corner Road

The Consultation document was discussed at the Parish Council meeting last night. It has to be noted that a hard copy of the document would have been very useful and would have produced more comments. It is easy to highlight sections and insert markers for discussion in a hard copy Consultation 421 and this is impossible to do for Councillors reading the document independently online. Several Comments noted. Q22 process Councillors do not like and do not read online documents. However Councillors would like to make the following comments. [see comments 422 and 423] Several Councillors hope to attend one of the proposed exhibitions and may be able to make more informed comments then.

Welcome the publication of this document. I'm appreciative of both of the amount of work Consultation 425 which has been involved in producing this document and its technical papers, and of the Support Noted Q22 document opportunity to comment. As Chairperson of R.A.D.A.R., I would like to make the following points regarding Chippenham : - Whilst I am pleased to see the removal of Westinghouse Sports & Recreation Ground from the "Housing Element" of the Core Strategy, I would strenuously request that it should be included as part of the "Green Infrastructure Strategy" without delay !! Recreation Grounds of such Comments are noted. The key principles which unique value to the local Community should be "Ringfenced" and protected by Wiltshire Council underpin the proposed strategy for Wiltshire within a given area of this Core Strategy. I am unable to find such an area into which this including Chippenham are set out at paragraph comment should be included. Previous to this Consultation, I have taken part in two previous 1.2 of the draft Core Strategy, one of which refers Consultations where Westinghouse Sports & Recreation Ground was identified as a site to be to protected by Local Residents ! I trust that this Consultation Comment will not be declared ‘protecting and planning for the enhancement of invalid due to the "Removal" of Westinghouse Sports & Recreation Ground from the Core the natural, historic and built environments, Natural Strategy document, as this would render six years of Continued Consultation, to identify 430 wherever possible, including maintaining, Environment; Chippenham Westinghouse Sports & Recreation Ground as a significant Community Asset, as unimportant enhancing and expanding Wiltshire’s network of Site Selection in the eyes of Wiltshire Council. From my visits to Cabinet, over the past eight months, I know green infrastructure to support the health and that "Engaging with the Local Community" is how Wiltshire Council is moving forward. I would, wellbeing of communities.’ Planning permission therefore urge Wiltshire Council to show that six years of highlighting Westinghouse Sports & has recently been granted for development of Recreation Ground has not been in vain !! Westinghouse Sports & Recreation Ground is STILL Westinghouse Sports Ground. Therefore it is no IN USE !! I was very sad to learn that, Spatial Planning were under the mistaken impression longer appropriate for the site be included as part that it was a derelict site !! I would strenuously urge Wiltshire Council Officers to CHECK ALL of the Green Infrastructure Strategy. FACTS for themselves first, rather than be misled by Agents and Applicants. There is a lack of Good Quality Recreational Facilities within Chippenham. Westinghouse Sports & Recreation Ground would make a fantastic Sport Hub for the Local Community within Chippenham. It has good links to Local Communities, is a safe and secure Ground as it is COMPLETELY Cross Comment No. Comments Officer Comments Issue Reference By LANDLOCKED, and is accessible to the Local Community for the very purpose it was always intended for. Westinghouse Sports & Recreation Ground will have a much larger significance within the next year. The Pavilion, Bowls Green & Hard Tennis Courts were opened by Lord Burghley, 6th Marquess of Exeter, in 1937. Best known for the Burghley Horse Trials, Lord Burghley was also a great Olympian. The Olympic Games of 2012 will be hosted by the United Kingdom. Indeed, the Torch will come through Salisbury on its route to London. Clearly, Wiltshire Council values the importance of the Olympic Torch coming through Wiltshire, indeed, maybe the Olympic Torch could come to Westinghouse Sports & Recreation Ground, in recognition of the fact that it was opened by Lord Burghley? . I hope, also, that Wiltshire Council will value the need to protect such a valuable Community Asset by protecting it within the Core Strategy Document! Wiltshire Council are now looking to "Put Forward" sites for inclusion into the Fields In Trust 2012 Challenge ! What cudos would come forward to Wiltshire Council if Westinghouse Sports & Recreation Ground - with facilities opened by such an important Olympian as Lord Burghley, were to be put forward as a "2012 Field" !! In Conclusion the Westinghouse Sports & Recreatopn Ground should be retained as Open Space for the Local Community, as a Recreation Ground for which it was intended or as a Community Facility which is sadly lacking in the Cepen Park Wards.

British Waterways is surprised that the Kennet & Avon Canal is not mentioned in the Spatial portrait of Wiltshire and is not shown on the map. The Council is gradually understanding the full list of benefits that the Canal brings to the region at present, and its importance in shaping the County in the past. We therefore feel that the Canal should be afforded the 449 importance it deserves; Its omission is regrettable. 2.7 The Canal transcends several Wiltshire Council will address this omission. Chapter 2. Q22 administrative boundaries and can act as a catalyst for improving collaborative working between different Local Authorities, all of whom have the same goals to improve the waterway corridor. 2.18 Whilst Green Infrastructure is defined later in the document it would be better to add a footnote at this point to define it correctly from the outset.

The core policies set out in chapter 6 are the guiding principles for the location and design of all development, and need to be placed at the front of the document before chapter 5, not left until Consultation 457 the end, giving the impression that they are an afterthought. I agree with the content of many of Comments noted. Q22 document these policies, but without clearer and more specific guidance on how they will be achieved they are unlikely to become a reality.

The consultation process is not user-friendly. Future stages of consultation will need to consider Comments noted. Every effort is made to ensure how to engage ordinary people without requiring them to become planning experts overnight! I the document is readable and understandable to Consultation 461 am left feeling that my views are unlikely to make any difference in the face of pressure to all. It is also necessary to ensure that the Q22 process develop and changes in government policy. Instead I am expected to accept that development document is detailed enough to withstand scrutiny is in the public interest and economics takes priority over climate change. and be considered sound. Cross Comment No. Comments Officer Comments Issue Reference By Strategic objective 1, Delivering a thriving economy and core Policy 25 The Kennet & Avon Canal contributes to the economy of Wiltshire in a number of ways. Not only is it a valuable tourist attraction, attracting day visitors and holiday boaters alike, (who make a siginificant contribution to the local economy), but the waterway infrastructure also supports many SME's in the form of marinas, boat builders, hire companies etc. It is important to understand that the waterway is a non-footloose asset and more flexibilty is needed to ensure that Core Policy 25 does not exclude the very facilities needed to promote and expand this valuable asset. As an example the creation of a Marina with chandlery and boat building yard would provide rural Comment noted: a policy with regard to canals employment and bring money into the local economy by increasing visitor spend at other will be included in the next draft of the WCS. It is 463 existing facilities such as local shops and pubs. Such facilities need to be located adjacent to SO1 the intention to save the existing Canal policies of the waterway, but due to the area of land required, cannot be viable in urban locations. Such the Kennet Local Plan. facilities may not be able to meet the precise criteria of the policy in that they cannot necesessarily re-use buildings or contribute to food production or the installation of broadband etc, but they nethertheless meet the aim of the policy in providing diversification and employment in rural areas. It is however noted that proposals which promote tourism in the rural areas will be supported. The possibilities of the Canal towpath carrying telecommunications routes to support rural broadband should be fully explored. At present the national towpath network carries over 9 kilometres of BT and B Sky B cables as part of the Digital Britain strategy. Strategic Objective 3 and Core Policy 29 and 31. We note the Council's aim to increase the range of housing type and choice to meet the needs of as many residents as possible. The section however does not adequately acknowledge or support housing choices which do not involve the provision of traditional bricks and mortar type housing. This type of housing is not always affordable to,or welcomed by, all residents. The Council is aware of the number of residential boaters who have chosen to permanantly live aboard their boats, particularly in the Bradford on Avon area. British Waterways regularly observes some 17 boats moored in Wiltshire which we believe may be used for residential purposes. Many of these residents would not label themselves as gypsies or travellers and therefore their needs are not adequately met by policy 31 either. The congregation of these liveaboard boats for long periods along the towpath in specific neighbourhoods can cause problems and often gives rise to complaints from other boaters and residents. The majority of these residential boats do not move sufficiently to meet British Waterways' mooring guidance. In theory, we should take action under our enforcement processes. If they fail to heed our fair warnings of the need to move more frequently, the process requires us to seek a court order enabling us to exercise our statutory powers to remove the boat from our waterway.The effect of this action could be to Comments regarding the needs of canal residents make the boat occupants homeless, thus thrusting them onto Council waiting lists. Our 472 noted. Consideration will be given to providing SO3 moorings guidance emphasises the need for increased provision of long term residential more detail on this policy area. moorings, ideally in off-line locations but also in suitable locations along the offside - the bank opposite the towpath side. In principle, we are very supportive of residential use of boats - they add colour, life and greater sense of security along the waterway.The provision of such moorings for residential purposes would allow better control of the impact of unauthorised 'liveaboards' in honeypot locations whilst allowing residents a greater width of choice in the type of housing available to them. Similar locational criteria to that mentioned under Policy 31 could be used to determine if a particular location is suitable. Carefully located marinas could be used to provide additional berths or existing marinas could be permitted to offer a percentage of berths as permanent residential moorings. The Government's 'new homes bonus' is payable to Local Authorities is respect of residential moorings. Such new homes can provide environmentally low impact living without changing the character of the area and can widen the scope and choice of housing on offer. British Waterways would welcome the opportuntiy to discuss this further and we appreciate that much more work needs to be done not only to prove the benefits of permitting such moorings but to find suitable to locations. We would simply suggest at this stage that the wording of the Policy does not overly restrict the way in which housing is provided in order to allow these issues to be more fully explored. Cross Comment No. Comments Officer Comments Issue Reference By

British Waterways is pleased to support the forthcoming Green Infrastructure Strategy and welcomes the introduction of Strategic Objective 5 and in particular Core Policy 35 and 36. We would however suggest that the wording is amended slightly to ensure that suitable links to the G I network are provided and maintained to ensure maximum accessibility and usage, not just Support noted. Consideration will be given to the network itself. We believe that an appreciation of the impact of Development on existing adding reference to the need to provide and Linkages to GI 483 SO5 green infrastructure is important to the decision making process and welcome the requirement maintain links to the GI network for the pre- network for an audit of impact to ensure that any adverse impact is fully mitigated. We submission draft core strategy. particularly welcome the acknowledgement that the green infrastructure network plays such an important multi functional role and that the canal network in the County is embraced as an important part of that network.

Please find below, Malmesbury Civic Trust's responses to the questions posed in the Core Consultation 484 Strategy Document. For the record, while I registered to use the on-line response, I found it Comments noted. Q22 process rather frustrating to use and have therefore reverted to a more traditional method.

Noted objection to housing growth. Topic paper 17 paper sets out the progress made in The document is comprehensive and hopefully gives flexibility to deliver appropriate community determining an appropriate requirement and development in accordance with localism initiatives. In particular, the aspirations of Parish distribution of housing for Wiltshire from 2006 to administrations (e.g. paragraph 5.0.3) need to be addressed when considering the 2026 to inform the draft Wiltshire Core Strategy. development of specific Market Towns and should surely be given greater prominence in the This process considers the strategic objectives for document. At the Public Consultation / Exhibition on 18th July, we were informed that housing the county as well as taking into account local requirements had been carefully assessed and "not just allocated pro-rata across the County". factors and aspirations for growth identified No explanation was, however, offered of the reasons for Malmesbury's disproportionately high 496 SO3, CP2 through community consultation. Topic paper 17 Housing Malmesbury growth figure, contrary to Paragraph 5.9.3 of the Core Strategy. Malmesbury Civic Trust does sets out the evidence behind the housing not oppose growth per se, but feels that the calculation should urgently be reviewed. Moreover, numbers for each community area and includes given the criterion that decisions should be evidence-based, we recommend that, before further the feedback from the community localism event development is considered "toward the latter half of the plan period" (5.9.6), a further which directly informed the figure.Small sites will presentation should be given by Wiltshire Council to demonstrate how the numbers have been be allocated through either the community led derived, how the consequent improvements to the local infrastructure will be financed and neighbourhood planning process or another delivered and how the Town's essential character will be conserved. planning mechanism in close consultation with the local community.

SO8 and Core Policy 42 & 47 British Waterways welcomes the promotion of sustainable transport routes as an alternative to car travel. The canal acts as a sustainable transport route Noted support for core policies 42 and 47 and the with the waterway playing a role in widening travel choices for walking and cycling and freight promotion of the canal as a sustainable transport movement. The towpath links several of the larger towns in Wiltshire and provides a safe trafic route but also that it is important that contributions free route to the town centre from outlying areas. Sustrans route 4 for example links Bradford are sought towards any upgrade and additional on Avon, Devizes and Trowbridge. It is important to remember however that if such routes are maintenance costs. Any proposals for additional promoted for addititional usage it may be necessary to seek not only a contribution towards use of the canals will need to be weighed up 497 their upgrade but also additional maintenance costs in much the same way covered SO8 against other core policies including policies on Canals SO8 by the Green Infrastructure Policy. The promotion of water bourne freight is also welcome in biodiversity and geodiversity, landscape and Core Policy 47. It is possible to use te Kennet & Avon Canal for hauling low value, high volume, green infrastructure. The saved policies from the non time sensitive freight but it is acknowledged that this use may conflict with other aims of Local Plans may also include some existing Local the Core Policy in protecting the canal environment as a peaceful wildlife habitat for example. Plan polices on the use of the Kennet and Avon This is however an unresolved issue as a result of the multi functional nature of the waterway canal. This will ensure a balanced approach is and therefore the impact of proposals involving freight must be carefully weighed against all the taken to the use of canals in Wiltshire. other benefits the canal offers. Cross Comment No. Comments Officer Comments Issue Reference By Railfuture Severnside finds much in the Consultation Document that is very positive towards rail Noted support for the approach towards rail transport. We hope that the Core Strategy will work in conjunction with the proposals of last transport. The Core Strategy will work in 498 SO8 Rail SO8 year's Draft Local Transport Plan 3, including public transport hubs with improved interchange conjunction with the Local Transport Plan to between bus and train services. delivery transport measures in Wiltshire.

Core Policy 26 does not include water as a means of providing low carbon energy. The Kennet The proposed core policy 27 in the June 2011 & Avon Canal can be used for environmentally sustainable inititives and can contribute to consultation document identifies how standalone Hydroelectricit 510 renewable energy targets through on shore HEP, and the use of canal or river water for the SO2 renewable energy installations of all types will be y heating and cooling of buildings. Information on this has been provided to the Council in the encouraged and supported. past. Question 1 – The Parish Council do not agree with certain aspects of the proposed settlement strategy, in particular the classification of ‘West Ashton’ as a ‘large village’. Referring to the methodology used to classify the settlement categories (Topic Paper 3 – Settlement Strategy) there are several significant incorrect factors input for West Ashton. Page 10 of the Settlement Strategy, paragraph 2.25 defines a large village as having ‘more green score than red scores’ in the traffic light system used to score the settlements. In the appendices for the Trowbridge Community Area West Ashton has 1 green score, and 4 amber scores. The green score was obtained under the ‘basic analysis’ definition in the methodology, where it is incorrectly noted that West Ashton has a ‘food shop’ – With this factor corrected the score would drop to ‘amber’ and overall the village would have no green scores. In addition to this error, under the ‘Transport and Communications’ definition West Ashton is incorrectly recorded as having a daily bus service and a community mini-bus – both of which do not exist in the village and are a This comment has been incorrectly put in vital consideration when planning any future proposed development. Also under the ‘Leisure, question 22 and actually concerns question 1,2 & Recreation & Other Facilities’ definition West Ashton is incorrectly recorded as having a sports 3. The information provided about West Ashton pitch and a public house – both of which do not exist in the village. It should also be noted that will be used to update the assessment of West although the village does have a primary school, an extremely high proportion of the children Ashton and the allocation as a large or small attending the school do not live in the village. Based on all these significant inconsistencies the village in the hierarchy. Comments regarding the Parish Council strongly believes that West Ashton, with its non existing services and very A350 are noted and no development will take limited facilities should be classified as a ‘small village’, and as such only be appropriate for place to the East of Trowbridge until a satisfactory 523 very limited infill development. Question 2 – The Parish Council do not agree with certain West Ashton solution at the Yarnbrook roundabout has been Question 1 aspects of the proposed delivery strategy. Bullet point 1 – ‘… and infrastructure delivery…’ agreed. Regarding the development of Greenfield The section of the A350 running from Yarnbrook to West Ashton is already widely recognised sites, where possible the strategy looks to as one of the busiest and congested sections of this main road. It is imperative that significant prioritise brownfield sites, however where this is improvements are carried out to address this problem before any further increase in traffic flow not possible Greenfield sites have to be used. can be contemplated. It is not acceptable for such significant infrastructure requirements to be Grouping development on a single provides the subject to phased funding, when it is already recognised that these improvements are needed most benefit in terms of infrastructure and now. Bullet point 2 – ‘ …. And limit the need for development on Greenfield site’. This community facilities. No development will be built statement is somewhat contradicted by the fact that the residential allocation of 2650 dwellings on land that is flood risk 2 or 3. proposed for North Bradley / West Ashton (45% of the total suggested development), as well as the proposed 30 hectares of employment land proposed in the Parish of North Bradley (100% of the total suggested development) are located on Greenfield sites. Bullet point 5 – ‘… is resilient to the impacts of climate change ..’ This statement is somewhat contradicted by the fact that all the proposed development referred to in the previous point is adjacent to a recognised floodplain. Such proposed intensive development of these sites can only increase the possibility of future serious flooding problems in the area. Question 3 – The Parish Council notes that the ‘Infrastructure Delivery Plan and Schedule’ was only published on the Wiltshire Council web site on the 18 th of July (just over 3 weeks before the consultation deadline), and considers therefore that there is insufficient time to consider this information in detail, and make comment. Cross Comment No. Comments Officer Comments Issue Reference By Comments noted. Discussions have taken place with service providers to identity the infrastructure Any proposals for further development in the Devizes area should be dependent on the local needed to support growth in Devizes hence infrastructure being in place to support additional growth. The problems of pollution caused by requirements for investment in schools, the 531 excessive traffic must be dealt with, health services need to be improved considerably and Transport Devizes highway network, ambulance station and consideration needs to be given to how additional residents can be integrated into the sewerage treatment works. The Infrastructure community. Delivery Plan will be published alongside the core strategy to ensure these requirements are clear. It is abundantly obvious that noone involved with drafting this document has any idea what the Comments noted. Discussions have taken place word "sustainable" means. It is quite simply NOT sustainable to build more and more houses on with service providers to identity the infrastructure Greenfield sites without first attending to the local environment. Infrastructure issues are rarely needed to support growth in Devizes hence considered except as an afterthought but it is vital to ensure at the outset of any development requirements for investment in schools, the that the infrastructure is already capable of accommodating the new houses. Building the new highway network, ambulance station and houses and hoping that the infrastructure will be able to cope has never worked - the evidence sewerage treatment works. The Infrastructure is all around us, especially here in Devizes. By infrastructure I mean every local resource that Delivery Plan will be published alongside the core the new residents will use - this includes roads, water and sewerage, schools, medical and strategy to ensure these requirements are clear. social services and so on. Futhermore it is essential to ensure that growth in housing is The current proposal envisages housing coming accompanied by a local growth in jobs, otherwise the market towns and villages will continue to forward within the existing limits of development 532 Devizes be dormitories for the larger towns, and the roads will be clogged with people who work in one for Devizes. No additional sites on the periphery place and sleep in another, without truly belonging to either community. This sort of commuting of the town are proposed. The new strategic leads to increased traffic congestion and reduced air quality. As has been observed elsewhere employment site at Horton Road has been this is already a major problem, with many towns in Wiltshire suffering illegal levels of pollution. identified specifically to address the need for This issue alone should be a bar to many developments. Every proposed development, be it for more quality jobs in Devizes to seek to reduce the one new house or a thousand, should be considered on the basis of its impact on the local levels of commuting. Air quality issues in Devizes environment and on the community with regard to all the factors mentioned above. In most are being monitored and the proposed Devizes cases these concerns are set aside as irrelevant, or the impacts played down. Tragically for the Town Transport Plan together with proposed people of Wiltshire, many planning decisions are made for the benefit of developers by people polices to address air quality will assist in who don't even live in the county and have no interest in "sustaining" our quality of life. reducing pollution levels. In examining the approach taken by Wiltshire Council, we have had particular regard to national policy guidance in respect of the intended role of Core Strategies and the tests that should be applied to ensure that emerging DPD's are ‘sound'. This guidance is principally to be found in PPS12: Local Spatial Planning. Guidance set out in PPS12 (paragraph's 4.36 - 4.51, 5.52 and the boxed text refer in particular) and LDF Soundness Guidance from PINS dated, August 2009, makes clear that to be sound a Core Strategy should be: 1. Justified :PPS12 provides that to be ‘justified' a Core Strategy needs to be: Founded on a robust and credible evidence base; and The most appropriate strategy when considered against reasonable alternatives The robustness and credibility of the Core Strategy is in part being tested through this consultation process and we generally conclude that the proposals set out in the plan are This response is the conclusion to a number of Overall 543 justified. However in a small number of instances we believe that the plan is unsound and comments that have been responded to in other Q22 Strategy requires amendment. 2.Effective :The guidance set out in PPS12 makes clear that Core sections. Strategies should be effective. This means: Deliverable Sound infrastructure delivery planning Having no regulatory or national planning barriers to delivery Delivery partners who are signed up to it Coherence with the strategies of neighbouring authorities Flexible Able to be monitored In preparing the submitted representations, we have focused on the issues of delivery and flexibility - key requirements in testing the effectiveness of the Core Strategy. We have concluded that in a small number of areas the plan is unsound and requires amendment. 3. Consistent with National Policy : We have concluded that whilst the Core Strategy is generally consistent with national planning policy guidance, in a small number of instances, it is not consistent with this guidance as a consequence is at present unsound. Policy CS1 - Settlement Strategy Paragraph 1.7 - We support the 3 over arching objectives. 570 Support noted. Chapter 1. Q22 See accompanying submission document. Cross Comment No. Comments Officer Comments Issue Reference By Noted the options were framed to encourage CS1 Settlement Strategy We support the 1 strategic objectives, para 3.2, but not the manner in further debate over Chippenham and the results 577 which they have been applied to Options 1 and 2. See accompanying submission document for Chapter 3. Q22 will be assessed in identifying one option for the more detail. next version of the document.

Policy CS21 - Additional Employment Land We generally support the policy and its purpose. We argue that policy is deficient in (4). ‘Realistic choice of means of transport' is meaningless. Should be amended to afford priority to sites offering an excellent choice of transport modes for employees and client base, taking into account the nature of the employment use and the need to reduce reliance on the private car. Should also be amended to adopt a sequential approach to assist and afford primacy to Town Centre regeneration. Policy CS22 - Existing Employment 580 Support noted. SO1 Sites We support spirit and purpose of policy. Criteria 5 should refer to market evidence offering unencumbered asset for sell / to let at realistic market levels for at least 6 months. It should adopt same approach as CS32. Account should also be taken of potential infrastructure improvements that will enhance site attractiveness for employment that will come about under Core Strategy LDF process. Policy CS23 - Economic Regeneration We support the policy in full. See accompanying submission document for more detail.

As a ‘Local Service Centre’ the Parish Council accepts that modest levels of development may be considered appropriate for Market Lavington. However, in order to ensure that any such development is sustainable it insists that it should be delayed until the transport and highways management issues that seriously affect the village are resolved. The Parish Council would also request that any further increase in housing development in the village should be accompanied by future commercial development. The Parish Council would like to re-submit the list of ‘Principles’ that it considers should be taken into account for assessing potential further development of the village, that were submitted at a previous consultation opportunity – Principles for assessing potential further development of the village. 1.1 The village culture and “rural feel” and characteristics of a ‘village’ should be retained and pressure to grow into a town should be resisted. 1.2 Previous developments on a scale greater than neighbouring villages Support for Market Lavington as local service have caused the mass of the village to approach its upper practical limit. 1.3 The medieval centre is noted. It is likely that development in all layout of the village should be conserved. This layout of narrow streets makes further large- of the Devizes Community Area will need a scale development impractical. 1.4 A ‘green-field’ separation between Market Lavington and the proper transport planning. The approach to non- 581 surrounding villages of West Lavington and Easterton should be retained, offering clear Devizes Question 1 strategic settlements is being revised , however boundaries between the villages. 1.5 The narrow roads within the village are currently causing the majority of the comment would seem to better difficulties due to the conflicting needs of passing traffic and residents needing parking spaces. suited for consideration in a subsequent There have been documented difficulties with the access of emergency vehicles within the document such as a neighbourhood plans. village. Road access and junctions further out, around the periphery of the village, are not suitable for further significant traffic growth. 1.6 There should be no further encroachment of building on southern side of the village and on the protected northern slopes of Salisbury Plain 1.7 Any development should be within the existing ‘envelope’ as specified on map 28 of the previous Kennet Local Plan. 1.8 The Secondary School is at capacity level, but could expand with new buildings. St Barnabas Primary currently has space for approx. 45 extra pupils. 1.9 Despite the growth in population, the number of shops and services has been decreasing. This may be due to a lack of parking facilities driving shoppers further afield. 1.10 The environmental impact of creating accommodation for commuters who work in distant towns such as Swindon, Salisbury and Trowbridge should be considered. 1.11 Wessex Water has confirmed that the sewerage system for the village is close to capacity. Cross Comment No. Comments Officer Comments Issue Reference By Paragraph 6.2.1 of the June 2011 consultation document refers to the settlement hierarchy. There is no legislation for meeting CSH standards in full and the proposed WCS policy does not duplicate any legislation. The proposed policy CS26 Sustainable COnstruction and Low Carbon Energy We support 6.2.1. Entirely correct allows for flexibility by stating that "In all cases the Objection to approach. We object to 6.2.5 as it fails to consider Spatial Strategy and thereby provide a fully council will have regard to the impact of these energy integrated policy framework. We object to specifying energy performance standards; Code for requirements on the viability of development will performance Sustainable Homes and BREEAM as it is over prescriptive and covered by other legislation. We 582 be taken into consideration" and hence is not standards and SO2 object to Sustainable Energy Strategy unless primacy is afforded to location and full weighting considered to be overly prescriptive. The Sustainable in any assessment given to the stated Core Strategy objectives recognising Topic Paper 11 proposed requirement to prepare a Sustainable Energy content; including inter alia para 3.3, 3.5, 6.4, 6.5, 6.9, 7.3, 7.5, 8.2, 8.5 and 8.16. See Energy Strategy is intended to encourage low Strategy accompanying submission document for more detail. carbon development, and will help ensure that developers don't opt for cheaper strategies in the earlier phases which jeopardise the ability of the development to achieve significant carbon savings in the longer term.

CS28 Affordable Homes General support of policy. We consider that clarity is required on Support noted. Further detailed guidance will be 583 whether the size and mix of affordable housing is to be negotiated on a site by site basis or led SO3 produced if necessary. by a Strategic Assessment. See accompanying submission document for more detail.

It is recognised that cycle ways form part of Wiltshire's Green Infrastructure network, and any CS35 Green Infrastructure General support of policy. It should provide for the inclusion of potential opportunities to improve the sustrans 584 sustrans cycle route and any new linkages made to it. See accompanying submission Cycle ways SO5 route and linkages to it will be explored in the document for more detail. preparation of the Wiltshire Green Infrastructure Strategy.

CS38 - Historic Environment General support of policy. We argue for inclusion of Scheduled Ancient Monuments to the list. CS39 - Housing Density We offer general policy support, except; The inclusion of a minimum density at 3dph is in direct conflict with latest revision to PPS3. If a General support noted. Comments regarding 586 density target is to be set on strategic sites then it should allow for exceptions and be calculated Changes to minimum density criteria will be SO6 on an average basis across a masterplan area. We object to ‘appropriate levels of comfort and considered. enjoyment'. Highly subjective and ill defined. See accompanying submission document for more detail.

Support noted. The requirement for a sequential assessment is provided through PPS4 and we CS41 Retail & Leisure General policy support. We consider that 6.7.5 should require a are advised not to repeat national policy. 588 SO7 Sequential Assessment. See accompanying submission document for more detail. However it will be looked into whether the policy can be strengthened to include reference to the sequential test. Cross Comment No. Comments Officer Comments Issue Reference By

Noted support for CP42, 45, 47 and 48.The transport policies do seek to promote linkages CS42 - Sustainable Transport General policy support It should however provide for the and connectivity by modes of transport other than inclusion of new criteria ‘ promoting linkages and connectivity to the Town Centre by models of the private car and this would include to town transport other than the town centre'. An assessment of priority of the identified criteria is centres.Noted comment that the criteria in CP42 required. CS43 - Transport & Development Support policy. We would argue the inclusion of should be prioritised. The policies are designed to new criteria to be demonstrated; ‘ An assessment of the anticipated carbon generation by be flexible so the criteria can be applied on a TransportClim 589 SO8 SO8 modal transport choice and cross reference with CS25 requirement for a Sustainable Energy case by case basis. All proposals will be required ate change Strategy'. CS45 - Transport Strategies Support policy. Argue for addition to policy to coordinate to submit a Sustainable Energy Strategy - this is with the Spatial Strategy and CS42. CS48 - Strategic Transport Network Support policy Argue covered under core policy 26.The Strategic the inclusion of the Sustrans Strategic Cycle Network. See accompanying submission Transport Network focuses on modes of transport document for more detail. used for medium to long term journeys whilst generally cycling is prioritised as a mode of transport for local journeys.

Yes thank you. There is a presumption in the Framework that changes to some of the most Further consultation will be undertaken for the beautiful countryside in Britain should automaticall go ahead without further submission draft of the core strategy. The 590 consultation.Where is the localism in this .? Secondly,Nearly all the towns mentioned are consultation document includes measures to Question 2 already unable to handle their motor traffic problems. These need to be addressed before even promote sustainable forms of transport (SO8) and more building is considered.(My own town of Marlborough is at times completely impassable) provide adequate infrastructure provision (CP3).

Question 21 - Correct Subjects Covered A rational and suitably weighted assessment of all key Spatial Strategy selection criteria is required for all potential Chippenham major growth sites, both employment and residential. In particular a transparent and logical assessment of Chippenham Options 1 and 2 (CS5) against the previous ‘Preferred Site' of Chippenham East is essential for the formulation of a credible plan. Question 22 - Other Comments The emerging The evidence base for the Core Strategy has Core Strategy policies are often contradictory and in consistant. The application of the been prepared in line with national planning emerging policies for site selection, namely Options 1 and 2 for Chippenham (CS5) is policy. Topic Papers 17 and 14 set out the unexplained and does not withstand scrutiny. A detailed examination of the evidence base housing requirements and site selection process leads to an inevitable conclusion that major development to South of Chippenham conflict with respectively. There are a number of statements the stated over-arching objectives of the plan, the strategic objectives and the majority of the 591 alluding to sites in Chippenham not being Chippenham Chippenham Community Area objectives. A fundamental re-examination of the housing prepared in line with policy within the document. allocation numbers, the Sustainability Appraisal and the Spatial Strategy for Chippenham is However, the process for site selection is essential. Failure to do so will produce a Draft Core Strategy that is unsound as it fails to considered sound at this stage and a number of recognise the evidence base upon which it should rely. The 'evidence' base is, by its own pieces of evidence such as Transport studies are admission, guidance rather than evidence. This is unsound and an unsuitable basis on which to being prepared for the pre-submission draft. formulate policy and identify strategic sites. The Sustainability Appraisal needs fundamental reconsideration using bone fide evidence, not platitudes. The Council are therefore urged to formally delete Options 1 and 2 and reinstate the Preferred Option, land East of Chippenham, which is properly grounded in the evidence base of 29 See accompanying submission document for more detail. Cross Comment No. Comments Officer Comments Issue Reference By

I have had a brief look at the Core Strategy consultation document on the internet. It could be my superficial understanding, but I can find no reference to the A345 and hence do not understand whether it is expected to sustain increasing freight usage or be intended for local access only in respect of freight. We ask that consideration be given to either recognising the Comments noted. Core policy 47 sets out the increasing through freight traffic and up-prating it in terms of width, quality, and signage or to generic approach to freight. Proposals for 593 SO8 Freight SO8 take measures to restrict the traffic levels or speed. To do neither is to simply leave ourselves at controlling freight on individual roads should be the mercy of freight drivers understandably seeking the shortest route and following their addressed through the freight strategy. satnavs. If for reasons of national policy or budget constraints neither option can be properly adopted then we ask that at the very least the road is made as safe as possible within our Parish boundary by means of speed limits calming and/or signage.

I am late into this process, and as such have not been able to digest much of the content. Were I a holder of a Degree in Town and Country Planning, perhaps the oblique, political and non-specific use of much of the language could be de-coded in a meaningful way. However, I am not - so I have to try and articulate frustration and some anger and dismay in a cohesive manner. One is left with two overarching impressions. First; the entire document is written considering the vested self interest of developers and other parties, who 'consult' with local and national government. It is they, and not the communities or their residents who will benefit from much of the strategy plan. In any moral sense this is wrong. Anyone with a vested self interest, for example employees, or former employees of developers, or companies providing lobbying services to Government, Local Government and Councils should be specifically disbarred from the consulation process. Second; I certainly see NO EVIDENCE to support the implied view that the opinions and interests of citizens and residents were central to the recommendations of this strategy document - the reason for that is absolutely self-apparent. Residents would never endorse the widescale development that will result in the permanent destruction of agricultural land and removal of natural amenity from their doorstep. On a personal level, I feel I have never been 'engaged', or I would have been writing these negative views long ago. I could express objections on a general level across many parts of the county, but lets try to be Comments noted. The Core Strategy proposals objective and address my key concerns as a Chippenham Resident. I moved to are supported and justified by evidence set out in Chippenham 18 years ago, because of the urbanisation of farmland at Pewsham. That the Topic Papers. Evidence gathering is ongoing development spawned some community benefit - a new primary school, four shops and a new and further work will be taking place to ensure Consultation 606 Q22 pub. A new by-pass road simply re-routed the congestion from one bottleneck to another; no they are as up to -date as possible to ensure that document through or local traffic problems were actualy solved. The completed doctors surgery came the Core Strategy is a sound document. Evidence several years later and finally a community hall, years later than promised, but Chippenham includes having regard to the views of the local itself and specifically the East of Chippenham did not materialy benefit in terms of community expressed through consultation. infrastructure. Indeed it was not until 10 years later that a third secondary school materialised and later still new sports fields @ Stanley Park - a fine facility, but years late. My point is that development on the scale of Pewsham bought little if any benefit to the town; the biggest majority of my neighbours work in London, Reading, Bristol, Chetenham, gloucester, Swindon etc - this is where they work, having to use the crowded and substandard road infrastructure, and typically, these places are where we all spend most of our money. As a retail centre, Chippenham Town Centre is a disgrace for a town of 30,000+ (and an even larger natural catchment in the hinterland). The town centre has actually become much worse since I moved to Chippanham, as its true status has been re-focused from market/community town, to dormitory town. The huge development in the 1990's of Cepen Parks North and South delivered exactly one new supermarket, one new hotel/pub, one new petrol station and a half completed by-pass; which in fairness provides 'some' relief to through traffic, but is far from the true by-pass that the main A350 needs. There is a familiar pattern emerging here - Developers get their way, they build, they deliver minimal benefit to the overall community and they move onto their next green-field project and profit centre. The entire core Strategy plan is Developer centric, not resident centric I believe that the plan itself is so non-specific in what will happen Cross Comment No. Comments Officer Comments Issue Reference By where, that it is an obscure means to an end. I see this as telling the residents of all sorts of things that might happen, with no disclosure of what will happen. Where is your accountability in this? How can residents excercise views and opinions held or expressed elsewhere that the strategy plan is all about the vested interests of the same consultants who helped to put it together. Chippenham, probably no different to Trowbridge, Salisbury, Calne, Devizes does not need more houses on green field sites. It needs the decaying infrastructure to be repaired and improved before any further new homes are built. It needs a town centre that is improving, not decaying month on month; it needs a County Council with the vision to recognise that they are the responsible for many of the causes of the decline that leads to the decay - and the answer is NOT to cram in even more house; spawing even more long distance communities and robbing those of us that have lived here for years of open space and natural amenity. Finally, if this was a true strategy it would address much more fundamental issues - Why do farmers so readily cash in their land for building; because agriculture is poorly supported at a strategic level ; we would sooner import than produce at home. Why does central government construct its' national house building policy based solely on mathematics and not on the needs, infrastructure, social and cultural, of the existing communities and those who will move to places that already cannot cope. In closing - the Strategy plan makes a number of non- enforceable claims that new jobs will be at the core of the justification to build 1, 2, 3, 4 thousand new homes in Chippenham over the next 15 years. And yet, what we see in reality are many 'real' jobs leaving the town, only ocassionally being supplemented by lower grade service industry positions. Chippenham is no longer a market town and a community where people live and work - it is a dormitory town where people live and commute from. It is my opinion that you guys urgently need to fix the former, before trying any enlargement which will simply grow the latter. I shall continue to read the plan with interest and concern, but would ask you to understand that there is almost not one shred of NIMBY in my opinions, I am just fundamentaly oppossed to growth for the benfit solely of developers, when there is no tangible and deliverable benefit for the current, and all those future new residents A Strategy is meant to meet an objective. The objective of this Strategy is stated to be the delivery of new jobs and the infrastructure required to support them (1.3) First problem: There is little evidence on why this was selected as the fundamental objective. There are several The key economic objective of the Core Strategy references to out-commuting as a "bad thing", but no comparative evidence that this affects have been derived through consultation and Wiltshire more than anywhere else (e.g.Surrey?). Second problem: Having stated the advice from both the public and numerous partner objective, one might expect the document to give great attention to how the desired new jobs organisation and bodies across Wiltshire. It has can be encouraged, what kind of jobs these might be, and how business or service institutions been made clear that during this sustained could be incentivised into the county. There is very little on this – possibly because nobody has economic downturn the plan should prioritize much of an idea how it can be done. Absent that crucial building-block, the vast bulk of the economic development. The primary concern with document then proceeds to concentrate on the housing-development that would be needed to regard to economic development and commuting support the (as yet non-existent) jobs. Third problem: The Strategy is in danger of putting the is that those who work in Wiltshire earn cart before the horse. Build lots of houses, attract lots of people to come and live here (where significantly less than those who commute there are no jobs); and then businesses who observe the available new labour will come and outside the county to work. In this way the Overall 607 set up shop. This seems a pretty aspirational and woolly kind of logic for such a major economic objectives look to bring opportunities Q22 Strategy document as this. There is no necessary connection between additional housing (additional for higher skilled jobs and modern businesses population) and additional local economic/business activity. New residents may still simply out- into Wiltshire. The number of houses being commute. The only exception to this would be if the incomers were economically self- planned for in the strategy aims to support this sustaining through pensions or state support, in which case they would in theory provide economic activity without putting unsustainable underpinning for additional retail and service employment. But this is surely not the economic pressure on the environment. Topic 17 details model that the Strategy intends to bring about. Yet on this very thin logic the Strategy goes into how this balance between economic growth and enormous detail about the precise locations of new housing, with some huge local community environmental protection has been considered. effects and some extremely rapid development timescales. Fourth problem: The Core Strategy The Core Strategy is being prepared in line with is produced in advance of the government's new thinking on planning frameworks, in advance Localism Bill and the latest NPPF and has been of the Localism Bill, and in advance of finalisation on how and when Neighbourhood Plans amend to reflect these documents as they should be developed. While this may be some extent necessary, the absence of clear develop. information on those other initiatives would suggest that a Core Strategy written in 2011 should be far more conditionally worded and should, in particular, have a much more phased approach Cross Comment No. Comments Officer Comments Issue Reference By to its introduction. That is, it should clearly allow for experience to influence the final arbitration of the strategic elements – how many jobs are really likely, how many houses, what sort of effects neighbourhood planning/localism might have. None of these things can be certain at the time of this consultation. The economic objective behind this Core Strategy (more “domestic" economic activity in Wiltshire) may -- or may not -- be rational. That is not at present clear. If it was clear, we would not necessarily oppose it, but we do suggest that to build a Core Strategy essentially around housing expansion -- which will obviously unleash a string of speculative and potentially environmentally-damaging development -- is rash. We would recommend that the document be re-worked in a much more guarded and conditional manner, building in more cautious and experientially-based decision-making processes and phasings.

This consultation 'web site' is very cumbersome to navigate around. I would imagine that many residents will try to find where they should leave their comments but give-up before they Consultation 613 manage to navigate their way there. That is assuming that they have 'registered' in the first Comments noted. Q22 process place. Are you trying to discourage residents from taking part in this exercise? Is there any way to find out how many people have viewed this document but not left a comment?

Reference 5.3.3 Hilperton village and the map on page 54. In paragraph 5.3.3 the Council purports to recognise 'that the historic core of Hilperton has a separate and distinct identity as a village'. However the map on page 54, whilst identifying Southwick, North Bradley, Yarnbrook This matter is addressed in response to ID 241 625 and West Ashton as separate villages, does not show Hilperton as a distinct village. It would CP7 General Trowbridge above. therefore appear that the comments in 5.3.3 are mere lip service to the existence of Hilperton village. The strategy should ensure that any good intentions are demonstrated to be sincere and with conviction by clearly identifying Hilperton's distinct village character in its outline plans. Cross Comment No. Comments Officer Comments Issue Reference By The consultation document states that it wishes to protect Wiltshire's natural environment and strengthen our communities. These comments are specifically about the plan to build north of the Chippenham cycle track and to revive the plans to build across the river on the open farm and recreational walking areas there. Chippenham has grown at a pace for the past 20 years through large scale housing developments which now virtually surround the town and have erased all but the last valuable areas of green belt. The sustainability of this market town has already been severely compromised by allowing the town centre shopping area to degrade to Comments noted. A key challenge highlighted in an extent where the community now needs to go to Bath, Swindon (and increasingly Calne and the document is that Wiltshire is rural in nature Melksham) to meet their needs. The natural beauty of the areas that the document proposes to and that its high quality built and natural Natural build on is enjoyed by walkers, cyclists, joggers and dog walkers in large numbers and of all environment must be protected and opportunities 629 Environment; Chippenham ages and is home to a wide variety of wildlife. This aspect is clearly one of the few remaining to enhance these significant assets maximised. At Site Selection advantages of living in this once beautiful market town. Building on these areas will effectively the same time there is a need to plan for the result in the final destruction of the remaining character of Chippenham which is rapidly future needs for jobs and homes for our growing becoming an unattractive dormitory town. It is clear by viewing the map that the intention of the and ageing population. proposed new development is to build on these areas to completely fill in the segment of land surrounding Chippenham that remains green, beautiful, undeveloped and a valuable resource to the local population and to it's visitors. The strategy should be to protect the environment whilst allowing more modest but considered development - with matching investment in the town centre. This strategy seeks to eradicate and to build on these areas for purely financial reasons which I cannot support. The Planning Committee of Wootton Bassett Town Council discussed the Core Strategy at their meeting on Tuesday 2 nd August, and returned the following observations:- The Committee Comments duly noted. The Council is committed was asked to consider the document and decide upon any comments to be submitted to to maintaining the separate identity of the villages Wiltshire Council in respect of the Core Strategy. RESOLVED to return the following and preventing coalescence with Swindon. We comments:- a) The Planning Committee expressed concern at the loss of the rural buffer zone. have heard this wish from the community loud It was felt that there was a need to keep the coalescence policy strong, so as to protect the and clear. However this has to be taken forward Development Community Area from the expansion of Swindon. The Committee felt very strongly that Wootton by appropriate policy mechanisms. The old style West of Bassett should be kept unique and distinct from Swindon. b) The Committee expressed their rural buffer (as a line on the map) now duplicates Swindon. Wootton 635 support for strategic transport links, especially between Wootton Bassett and Lyneham. There Government guidance and is no longer allowed in Coalescence / Bassett was support for the possible re-opening of Wootton Bassett railway station, and agreement that that form. Accordingly, through various identity of road links will need to be improved if the change of use at the MoD base at Lyneham requires mechanisms including policies ensuring strong villages. heavy vehicle movement through Wootton Bassett. This raised the issue of a Wootton Bassett control of development in open countryside and by-pass through the possible extension of the Interface link, which the Committee felt would be via Neighbourhood Planning, it is intended to beneficial if it meant that the amount of traffic on the High Street were to be reduced. c) Overall, bring about the protection sought by other the Planning Committee are broadly supportive of the Core Strategy for the Wootton Bassett means. Comments about transport duly noted. and Cricklade Community Area. I hope that this is useful, Kind regards, Emily Maiden Administrative Assistant Wootton Bassett Town Council It is recognised that the document can be difficult for non-planners, nevertheless the document 1. I am not convinced that 'consultation' is the best word to descibe this process. The carries legal weight and needs to stand up to document is long, full of very long words and jargon. Some need to be defined. Spacial is not a scrutiny. National Policy is clear that specific rural word to use with regard to planning, and what does 'sustainable' mean ? 2. In chap 6 it is stated buffers should not be identified. The document is that the rural buffer ' is not defined'. For those villages near Swindon it must be defined, as s strategic document and specific infrastructure urban sprawl is of real concern to small villages. 3. Small villages are given a passing Wootton Number of 645 planning for smaller villages will appear in Q22 reference, whereas in reality they need to be part of a review of the infrastructure. We need Bassett Issues subsequent documents such as neighbourhood affordable housing, yet we have few employment opportunities and no regular transport to get plans. J16 comes under the jurisdiction of the to the large towns. 4. Junction 16 of the M4 has to be sorted out. It has been ducked for long highways agency, however, due to the junction enough - and any development in this area will impact directly on this village. We fully support being at capacity housing numbers in the area CPRE's view on this. and a number of development sites have been adjusted accordingly. Cross Comment No. Comments Officer Comments Issue Reference By

Overall comments. There may be changes as a result of the Localism Bill and the NPPF Because the development of large sites has not proved to be successful (as seen in Swindon) the strategic core strategy should not be site specific. It should just gave the numbers, the The Council will ensure that the Core Strategy is Overall 647 settlement strategy, and the policy guidelines so development could be determined at local compliant with the NPPF and the new Localism Q22 Strategy level. The use of vague terms such as "modest", "churn", "appropriately" should be avoided, or Bill as and when these documents develop. defined. All maps/drawings, should include the parish boundaries. These are important, especially locally.

Para 3.11 6 th Bullet. Delete this whole sentence. "Measures" are undefined but need to be These are outcomes that the further detail of the defined. New roads, or selective major imporvements to roads such as that proposed at strategy will seek to achieve and not detailed Yarnbrook conflict with the aim to manage transport in a sustainable manner as they will only conditions of development. That needs to be 648 increase the volume of traffic. The increasing cost of petrol/diesel is already reducing Chapter 3. Q22 expressed in policy. We will review and check the congestion. Para 3.12 Replace "appropriately" with, at the end of the sentence, "before the robustness of policy in achieving certainty and development is built." Reason: "Appropriately" is open to wide interpretation and could lead to clarity endless argument. Clarity is needed.

Core Policies supported. 24, 26, 28 29 30 33 35 38 39 40 41 43 44 46 47 49 51 Question 22 While there is reference to sustainable tourism in the aims, there is no policy to this effect. Noted. The policies under the objective for Overall 668 SO1 Q22 There needs to be one. There also needs to be a policy to protect the Best and Most Versatile economic development are being reviewed. Strategy agricultural land.

The document totally ignores any employment opportunities in agriculture and its many and Noted, this will look into and the possibility of 669 varied subsidiaries. Surely if economic growth is at aimed reducing the levels of out-commuting inclusion of a policy that supports rural life SO1 this basic industry to a very a rural county should at least be taken note of. considered. Essential to success in achieving this strategy's objectives is an effective linkage between development, climate-change/environment and affordability. Here the author just comments on the opportunities for achieving one facet of this linkage - Collaboration, e.g. in "Resouce Parks" to optimise the use of goods and materials in the Wiltshire economy: By 2026 we will have to be closing the loop by linking goods and services comsumption with intelligent, comprehensive residual value recovery from used products and materials. This will mean much closer collaboration by Wiltshire Council with goods and services supply chains, to achieve on a shared basis, much higher value extraction from the goods and materials flowing through the Wiltshire economy. A challenge - yes! But this future means the Wiltshire Council will no longer be expected alone to deal with Wiltshire's "not now needed/wanted" goods and materials. Future Vision Example: In place of "landfill" and today's limited "recycling" (granted, recycling in Wiltshire is now improving strongly). The Wiltshire Council works closely with major retailers (which already, are taking their first steps away from "we sell, consumers use & dispose") and other supply chain "players" to develop integrated "Resource Parks". These, offer retail Comments noted. These comments have been 671 SO2 services and to equally comprehensive and attractive standards, all the facilities necessary to passed to the council's climate change team. return used goods and materials into the new, loop-closing part of the supply "ring", which recovers the as yet unused, residual value in the used goods and materials. These used goods and materials go into remanufacturing (warranted to original performance standards) and to reuse where they generate addional value. Community Resouce Parks may include local pick- up/drop-off hubs to eliminate the traffic & emissions of today's abortive "white van" deliveries. The Resource Parks have their own fleet of electric local delivery vbehicles, (recharged from their own renewable power supplies) for those who cannot, or choose not to, visit the hub to collect or to drop of their items. The whole Resource Park is designed as a community asset with all the features required to make their use, and with it public participation in sustainable consumption, an attractive, desirable family activity. Financially, the Resource Park is run in a way which rewards the community with part of the savings made by markedly raising the value extraction from goods and materials and by minimising, or eliminating, what may well by the 2020s be the very high costs of continuing to waste the residual value in used goods and Cross Comment No. Comments Officer Comments Issue Reference By materials. (There are good industrial examples, including in Wiltshire, of the scale of the savings available from grasping the nettle of closing the consumption loop to eliminate "waste" in all its senses). NB: The author has no commercial interest in the ideas proposed in this comment. As a Wiltshire resident, the author would like to see Wiltshire taking a lead to gain the value benefits of optimising goods and materials usage in its economy, as suggested and/or by other routes.

This Foreword is a classic example of good-sounding words that seeks to conceal policies that contradict its tenor. The assertion that 'This consultation document has been shaped by your comments' is simply implausible. Wiltshire Council has never seemingly altered its thinking in any significant way following consultation exercises, but has carried on with its mistaken and destructive ideas in complete defiance of what people tell it. It even carries on in defiance of hard barriers to its mistaken ambitions. Anyone normal would think that the Inspector's views and the Government's decision on the Westbury Bypass would carry some weight with Wiltshire's planners. Instead they persist with their now grossly out-dated transport notions, pursuing the absurd concept of a strategic functionality for the A350. Not content with the horrible sprawling mess they have made around Melksham they pursue the ambition to make all of West Wiltshire like this - like something out of megalopolitan New Jersey. Not content with running down the centres of its towns like Trowbridge almost to the point of annihilation, they seek to create a tin-shed corridor alternative, entirely car-dependent (just as the oil is running out). This is the exact opposite of sustainability and of 'resilience' if that means anything. It commits West Wiltshire to being a run-down ribbon sprawl with dead towns The Core Strategy must be based on credible in a dead landscape, without coherent communities or any pride of place. This does not appear evidence using national policy advice and best to be a strategy for 'protecting Wiltshire’s natural environment and strengthening our practice. The majority of the housing growth being communities' , as claimed. It is much more about ambitions to increase the population of planned is to service the current population, Wiltshire, for an unspecified reason. There is an implied belief that somehow this improves Number of 676 housing over and above this is expected to Q22 prospects for those already there. The notion that adding population and jobs (even Issues provide some economic growth within supposing the strategy presents any evidence that it can bring in jobs - which it does not) helps environmental limits. Topic Paper 17 outlines the to improve the prosperity of existing communities is simply unfounded. It is a similar argument balance that has been sought between economic to that which says we should increase population in order to look after our existing elderly growth and environmental protection. population. This is merely to generate much bigger problems for the future in order to solve some perceived problem of the present (and there is no real evidence that it does even that). One does not approach sustainability (or the new cant word 'resilience') by deliberately going for growth in a domain of diminishing resources - the only growth you end up with is a growth of problems. This foreword talks about enhancing the environment - just where does its commitment to unfettered growth at all costs help enhance the environment? It also talks about the importance of addressing climate change - yet there is nothing in this strategy that seriously addresses the issue, while its main thrust towards car-dependent development can only have the result of significantly worsening Wiltshire's already bad performance. This dire strategy clearly ties itself to the hope that current Government thinking is all about growth before everything else. Who would want to bet that the Pickles/Osborne formula for the economy will last for more than a couple of years before the realities of a world of rapidly dwindling resources forces itself on such old-fashioned thinking and sane sustainable economic policies replace the old model? Where will Wiltshire be when all its core strategy assumptions have proved baseless? Cross Comment No. Comments Officer Comments Issue Reference By They were written by the same person. The spatial vision is consistent in that it seeks to improve the self-containment of the main RE Strategic objective 2 to address climate change. Recognition is required for the importance settlements thereby providing greater of the Green Infrastructure Strategy to provide connectivity within the natural environment at a opportunities for living, work and leisure without landscape scale to allow species to move in response to climate change. RE Strategic objective the need to out commute. It seeks to deliver the 677 Chapter 3. Q22 6 to safeguard and promote a high quality built and historic environment. Appropriate design jobs and homes to support viable town centres, of buildings and open space will provide breeding/nesting sites, a place to forage and access to not erode them. Evidence indicates that doing water for urban species. nothing would have the latter effect. This is not an attempt to empty town centres, but to support their long term prosperity and to provide much needed jobs and homes for local people. There is no understandable evidence given here to support the assertion that 'The strategy is to strengthen communities, wherever possible, by maintaining and increasing the supply of jobs'. There is plenty of talk about balancing these things without any explanation as to why the deliberate increase of population alongside provision of industrial land should magically created an increase in economic activity that would benefit the existing communities. The housing increases are well beyond anything that is necessary to deal with the needs of the existing community. Why should the provision of loads of Greenfield sites for housing and industrial development attract economic activity that ' strengthens' existing communities and 'increases the supply of jobs''? The assumption is that just the act of providing the space is enough for the market to provide the activity. At best this thinking relies on an old economic model of new towns like Milton Keynes or of growth corridors like the M4, highly car-dependent - if you provide the space for the activity, it arrives because the transport networks allow it to arrive. In the post-Peak-Oil world and the world in which we are supposed to be getting serious about climate change, this model is doomed. Activity will tend to stay where transport requirements are minimum or highly efficient. Road-corridor-based activity leads to highly distributed, Noted. Some parts of Wiltshire currently entropic populations, intrinsically unsustainable when the costs of transport increase. There is experience a very limited supply of new an argument (or rather an assertion for there is no evidential basis presented) in the strategy employment land that not only prevents new 688 Chapter 1. Q22 that Wiltshire is doing all this development in West Wiltshire in order to reduce out-commuting. businesses coming but at the moment is The Council adduced this argument at the Westbury Bypass Inquiry and utterly failed to justify preventing expansion and retention of our it. All the evidence is that providing road space moves activity further away from population, or existing business. at the very least more distant attractors become more powerful. Wiltshire's has an attraction for resident population in its as yet unruined environment. It has little attraction for economic activity. What after all has it got to offer beyond its agricultural base (which will suffer as Greenfield sites diasppear), its tourist activity (which is very important but likely to be adversely affected by this strategy) and military importance (which is undergoing retrenchment)? Planners always and everywhere like to toy with the notion of knowledge-based industries as a solution to supposed problems of unemployment. But there is nothing that Wiltshire can offer that makes it especially suited to this - it has no strong university or other research bases. On the other hand there are activity attractors over the border (Bath/Bristol, Southampton, Oxford) that are and will remain significantly stronger. As long as petrol is affordable all that extra population will do in West Wiltshire is increase out-commuting. When petrol is no longer affordable population will gradually move towards the strong attractors - all the West Wilts sprawl will remain without any real activity beyond what it had before but with a much bigger, if declining and increasingly impoverished population - the Detroit phenomenon. Cross Comment No. Comments Officer Comments Issue Reference By I note from the map of deprived areas that apart from strong military areas and the unexplained area in the SW of the County, the most deprived areas are concentrated in towns. The towns of West Wiltshire are clearly picked out as deprived. This being the case one would imagine The proposed housing figures, design policy, that concerned planners might be thinking in terms of policies centred on restoring hope to town affordable housing policy and sustainable centres instead of concentrating their efforts on creating new sub-urban and A350 ribbon construction policies seek to address the noted sprawl (all of which I have argued under Chapter 1 will itself become highly deprived as it will be issues. Indeed, the developments in and around unsustainable as transport costs increase). The arguments about need for affordable houses the West Wiltshire towns will be of a high quality, are well-rehearsed and habitually miss the point. You do not solve social housing needs on a and provide infrastructure for the towns. 'leaking bucket' principle. At best the actual provision of affordable housing falls well short of

40%, so that all the population brought into an area, with all its attendant problems, is a big The viability of building social housing without price for the rural community to pay for meeting its social duty of providing adequate housing for market housing is questionable, and would have those already in the area and in need. Local authorities need to get back to providing social to be funded by the public purse. Without housing through their own building programme, financed from the rates, and not through Government funding this is unlikely to happen. dubious development deals. For one thing it is not always apparent that 'affordable housing'

provided through such deals is actually serving the social need of the most deprived. But there The proposed housing figures are below that is an obvious spatial difficulty with the Strategy approach to housing need. It sees affordable identified by the Department of Communities and housing being provided as an add-on to large Greenfield sites. Yet those most in need appear Local Government household projections. Indeed, 696 to reside (in some way) in urban centres, according to the deprivation map. The consequence Chapter 2. Q22 for areas such as West Wiltshire this is entirely of the suggested strategy would seem to displace such people from town centres, further appropriate owing to the current out-commuting exacerbating the doughnut effect of existing policy - an empty decaying centre surrounded by flows. By providing fewer houses relative to an amorphous sprawl of housing and tin shed employment and retail. All the advantages of employment opportunities, the commuting flows urban, civilised living with a mixed social milieu, concentrated facilities (and often, especially are intended to be reduced, with a resulting with the west Wiltshire towns a good connectivity via a rail system) are lost, and nothing is decline in carbon release from transport. gained. Are you seriously suggesting (para 2.16) that concerns for climate change are central However, it must be recognised that in the to your strategy? At the same time as distributing population across Greenfield sites, entirely already stretched housing market with insufficient car-dependent and actually encouraging an increase in car journeys by increasing road housing provision that additional dwellings must capacity on the A350? Where are your calculations of the carbon consequence of this? be built. These will also benefit the local Similarly are you seriously claiming (para 2.19) to protect (and even enhance) Wiltshire’s high economy, by providing and supporting jobs and quality built and natural environment when the strategy is so clearly directed towards building by increasing the spending power of the vast sprawling housing estates and tin shed developments across west Wiltshire and ramming community. An appropriate balance between hugely damaging road schemes through highly sensitive landscapes and habitats of these factors has been struck and been found internationally important and endangered species, and which at the same time is most sound by an independent expert. obviously going to drain the hearts out of the existing urban centres? There is nothing in the strategy document which seriously contemplates what you would need to do if you seriously believed these statements to be more than pious words. Cross Comment No. Comments Officer Comments Issue Reference By Dear Mr. Kerr, Wiltshire Council’s Draft Core Strategy Members of Hilperton Parish Council have studied Wiltshire Council’s draft Core Strategy and have concluded that it does not represent a coherent plan for the future of West and North Wiltshire to 2026 and beyond. Last year we were led to believe that the abolition of regional allocations for building new homes in the county would allow us to decide how much development we wanted in Wiltshire and where we wanted it. Today we find that the massive housing estates and retail parts have not shrunk back from the green field sites where the developers would like to build them. Twenty thousand new homes and something like a square kilometre of industrial estates are planned for North and West Wiltshire by 2026 – homes and jobs for another 50,000 people. We question fundamentally whether this model of expansion can bring the economic growth the Council The Core Strategy has a number of policies that expects, while also meeting the needs of existing communities in an area where transport, aims to address a number of the issues raised in education and health services are already struggling to meet demand. Clearly past planning this response. Core Policy (CP) 6 details a plan policies have not worked, yet the Council’s Core Strategy is proposing more of the same:- More to regenerate Trowbridge town centre and CPs decline of town centres More characterless, car-based suburbia More traffic, congestion, noise 42 - 48 details a comprehensive transport plan for and pollution in both towns and villages More damage to the natural environment and loss of development and strategies across Wiltshire. The agricultural land More overloaded services Rather than reproduce these outdated policies in the housing and employment being planned for is blueprint for the next fifteen years, we ask the Council to think again and give us:- a) An overall based on the most up-to-date evidence available reduction in the housing numbers it has proposed for West and North Wiltshire, seizing the in line with Government advice as detailed in opportunity offered by the scrapping of regional allocations and fulfilling the promise of a new topic paper 17. While it is recognised that a ‘localism’ in planning policy; b) A more honest consultation which provides real data and maps Number of 709 number of Greenfield sites are being planned for Q22 on the traffic implications of proposed growth in our area; c) Much stronger policies to ensure Issues mitigation and measures to ensure continuing that people will have real opportunities to switch from driving to walking, cycling and travelling protection of the environment are being taken to by bus or train – a key objective of the Wiltshire Community Plan; d) A better and more ensure that sensitive areas are not damaged by informed appraisal of our real needs for new jobs and new homes; the relationship between development. New maps will be produced for the these needs and the skills we want to develop and attract in coming years; q more direct way to next draft of the Core Strategy. Finally it should meet the urgent need for affordable homes in towns and villages; e) The channelling of be recognised that the Core Strategy does carry developer funds away from building more roads and towards developing and improving town legal weight and as such needs to make sure it centres, creating ‘green infrastructure’ and supporting better public transport; f) The clear can stand up to scrutiny, however every effort is prioritisation of Trowbridge and other town centres for office development to bring vitality back made to make it legible for non-planning to central areas; g) Fewer new employment areas on the fringe of towns – less ‘tin shed’ land in professionals. the open countryside; support for rural employment, farm-based enterprises, local food and working villages; h) A sustainability appraisal that genuinely examines the environmental consequences of hot-housing Western Wiltshire, and looks at other options for development in the coming decades of climate change, peak oil prices, and shortages of food and water; i) A Core Strategy that is understandable to people rather than hiding its objectives in planning jargon and evasive verbiage; j) The publication of accurate maps to show the proposed locations of housing and employment areas and the roads and other strategic infrastructure and services that the Council is planning to provide for them. We consider that the present draft of the Wiltshire Core Strategy is not ‘fit for purpose’ and we ask the Council to think again. Yours sincerely, Marylyn Timms Clerk to Hilperton Parish Council

There is much in the proposed Core Strategy with which the Preservation Trust agrees, both in its broad provisions and in the Community Area Strategy for Bradford on Avon. Indeed, we think that there ought to be some toughening up in places, more attention to consistency in others and alteration to some provisions along the lines indicated. Chapter 1 Refers to the key 713 Support noted. Chapter 1. Q22 principles. In particular to the pattern of development (i.e. location of development) reducing the need to travel, planning of development to reduce out-commuting and, under economic growth, refers to self-containment of settlements. These principles need to be carried forward more fully into the Community Area Strategies, in particular for BoA. Cross Comment No. Comments Officer Comments Issue Reference By

There is much in the proposed Core Strategy with which the Preservation Trust agrees, both in its broad provisions and in the Community Area Strategy for Bradford on Avon. Indeed, we think that there ought to be some toughening up in places, more attention to consistency in others The general support is noted and welcomed. and alteration to some provisions along the lines indicated. Chapter 2 Again this chapter Policies will be reviewed to ensure that they are 715 refers to out-commuting, the ability of the planning system to influence greenhouse gas Chapter 2. Q22 both consistent and provide sufficient emphasis to emissions and the need for new developments to bring additional benefits to the community. ensure that development is sustainable. These fine words need to be carried forward into the detailed policies, with more emphasis, particularly in the Community Area Strategies which will form the basis for the production of neighbourhood plans.

Under ‘ Relationship with other plans and strategies' we are pleased to see the Wiltshire Joint Strategic Assessment listed. We would suggest that mention could be made of the Community Area JSAs which will be produced this year. We think an important missing entry in this section Noted. This will be considered within the next 719 Chapter 1. Q22 is any reference to the ‘Local Transport Plan - LTP3 2011-2026'. We suggest this should be draft. mentioned explicitly since Strategic Objective 8 (under 3.2) is ‘ to promote sustainable forms of transport' . ‘Infrastructure ... should also, where possible, bring additional benefits to the community as a whole such as town centre enhancements or cycle and footpath links. The level of infrastructure provision will need to reflect growth and demand for services within Wiltshire's communities.' In terms of Public Health we are pleased to see mention of active travel (walking, cycling) although this seems phrased as a passive process of waiting for a need to be evident. We Infrastructure will be essential to ensuring that would suggest that creating environments that encourage and support physical activity (to help development is sustainable. Core Policy 3 sets tackle a growing obesity problem) needs to be an active process. The health and economic out a list of essential and place-shaping benefits of increased active travel were highlighted in the Public Health response to the LTP3 infrastructure, including sustainable transport 720 Chapter 2. Q22 consultation. We believe that Wiltshire council could stress their commitment to designing measures, leisure and recreation facilities, open environments that promote physical activity in both the Introduction and Strategic Objectives of space and green infrastructure. This list is not the Core Strategy. This could be supported through use of the NICE (2008) Guidelines exhaustive and other forms of infrastructure will ‘Promoting or Creating Built or Natural Environments that Encourage and Support Physical be supported to deliver the identified objectives. Activity' - http://www.nice.org.uk/nicemedia/pdf/PH008guidance.pdf and the 2011 Active Planning Toolkit issued by Gloucestershire Council / NHS in league with NICE - http://www.nhsglos.nhs.uk/2011/05/active-planning-toolkit-launched (which includes a case study of the Gloucestershire Core Strategy 2010). Noted. The Council has a duty to work collaboratively with neighbouring authorities and General Comment The plan gives little consideration to the interaction between the west have regard for their plans. Wiltshire, Mendip and Wiltshire towns and locations in adjoining local authority areas such as Frome. This is BANES have continued to work together over Neighbouring 728 necessary in order to ensure cross boundary issues are adequately addressed. Mendip District issues particularly around commuting and Authority Q22 Council looks forward to working with Wiltshire and BANES to address these issues and transport during the formation of the Core DPDs achieve the wider goals of the area. Strategy. Nevertheless, help from community organisations will strengthen cross-border planning. This section should note that the plan has to be consistent with other relevant plans and Noted. The Council has a duty to work Neighbouring 731 strategies relating to adjoining areas. This will ensure opportunities to plan with adjacent areas collaboratively with neighbouring authorities and Authority Q22 are taken to deliver wider shared goals. have regard for their plans. DPDs Cross Comment No. Comments Officer Comments Issue Reference By The Spatial Vision is entirely laudable. How extraordinary then that the rest of the strategy document appears to have been written by someone else, since it seems to go out of its way to make the Spatial Vision an impossible ambition. How does massive Greenfield development away from town centres and served only by roads focus on sustainable development in Wiltshire's existing towns? How does linking these vast areas of housing and tin-shed development by road building bring about a consequent reduction in the need to travel? How is Wiltshire's important natural and built environment safeguarded by emptying historic town centres and shoving population on to Greenfield sites and driving roads through important landscapes and habitats ? How is the approach of building roads and neglecting railways (where in this strategy is there anything significant on encouraging rail use?) leading to a more sustainable approach towards transport? How is tourism encouraged by draining activity out of historic towns into sprawling New Jersey style developments strewn across what was important scenic and historic landscape? How does encouraging more car-based activity contribute towards tackling climate change? Strategic Objective 1: These are all motherhood outcomes. There is nothing in the strategy which gives cause for believing that these will be the outcomes. Providing space designed to encourage population increase and providing space for industrial or commercial use carries no certainty that the jobs will come to meet the needs of either the existing or the new population. In the world of cheap petrol there was always the possibility that failure to bring in activity would be compensated by allowing out-commuting. This is no longer the future - activity will go to places best suited or already adapted to it and population will drift toward it. Wiltshire has no special attraction for activity (except perhaps tourism in its historic centres and the strategy is really not doing much to help that) and They were written by the same person. The planners can't make it attractive simply by providing space and wishing for it to be used. This spatial vision is consistent in that it seeks to strategy is highly unrealistic. Strategic Objective 2: Astonishing that Wiltshire Council does not improve the self-containment of the main appear to have considered the carbon consequences of its transport ambitions at all. Strategic settlements thereby providing greater Objective 3: This appears to take for justification what might seem reasonable - the desire to opportunities for living, work and leisure without provide Wiltshire's people with adequate housing. I have suggested elsewhere, the need to out commute. It seeks to deliver the 750 Chapter 3. Q22 however, that building tens of thousands of homes for a new population being brought in is not jobs and homes to support viable town centres, a sensible way to address the needs of the existing resident population - it is the old and long not erode them. Evidence indicates that doing debunked Thatcherite notion of 'leaky buckets'. If there is a social need for housing it should nothing would have the latter effect. This is not an be addressed directly and in the old-fashioned way of local authorities building council houses attempt to empty town centres, but to support out of rates. To identify the places of greatest need (apparently concentrated in towns) and their long term prosperity and to provide much encourage the movement of the needy out into suburban and car-dependent sprawl is a recipe needed jobs and homes for local people. for further deterioration of town centres. It is also a recipe for increasing social exclusion. Those most in need of housing are likely to be those having least access to cars (and this is likely to be increasingly a problem as we move into the post-Peak-Oil world). Yet the strategy seems to be aimed at taking them away from towns where they at least have some access to public transport and dumping them in a world from which they cannot easily or frequently escape. The strategy of importing population is so incomprehensibe that one has to ask what it is that is motivating it. It seems to be that the Council starts with its ambition to create a high- capacity A350 corridor (why is never explained - no explanation made any sense to the Inspector at the Westbury Inquiry). It then sees the only way to achieve this, now that it has failed to demonstrate to central government that it should fund the ambition, is to get developer contributions to pay for it. So it proposes to import population to occupy the houses that the developers may want to build and then get enough money to build the road that links the sprawl. And what is the result? Either that the petrol runs out and the sprawl remains unserviceable, unsustainable, a dreary and slowly dying monument to Council folly, or that the huge housing estates and tin-shed business parks generate more and more traffic, fill the A350 and we end up with it much more congested than it is imagined to be at the moment. The vicious circle is complete - the road is built by importing the population to use it, making it more unusable than it is and presumably justifying a further round of 'improvement' or 'journey time reliability enhancement' or whatever cant phrase is to be used ( 'resilience ' probably), which of course means more import of population to pay for it. Strategic Objective 4: 'Resilience' again. Whatever this word means (good and thoroughly bad things can be resilient Cross Comment No. Comments Officer Comments Issue Reference By - Wiltshire Council seems to be entirely resilient to the impact of common sense on its transport policy) the key outcomes of this Objective appear to be pious words of hope rather than any likely outcomes of any policies revealed in the Strategy. Strategic Objective 5: I wish. The housing and transport policies in this strategy seem to be aimed at defying this objective. The bigger strategy ambitions (especially those for the A350) are clearly inconsistent with almost all of these key outcomes. Strategic Objective 6: Again I wish. The desires for improving the built environment are clearly belied by a strategy which seems to make a point of moving population into sub-urban sprawl. The concern for the environment of Stonehenge is pretty cool for a Council that has gone out of its way to increase traffic on the A303 with specific developemts as at Solstice Park and which has lobbied time and again to increase the capacity of that road. The latest megashed development at Solstice Park approved so enthusuastically by WC will have a significant visual impact on the World Heritage Site. Strategic Objective 7: Again the strategy seems perversely aimed at not achieving this objective. Strategic Objective 8: Exactly the same criticism. Whatever the weasel words that say otherwise, this strategy so obviously sets out to promote unsustainable transport modes. Wiltshire Council is not interested in supporting its rail services in any meaningful way and yet persists in its decades-out-of-date road transport thinking. Indeed it is arguable that the most significant part of this strategy (its spatial policy) has been determined primarily by its obsession with making the A350 a major highway from the A36 to the M4. Strategic Objective 9: So we need to provide the infrastructure to serve the population we are importing in order to get developers to pay for the road infrastructure we want? Strategic Objective 10: You could, of course, reduce the risk of flooding by not concreting or tarmacking half of West Wiltshire.

For: Tisbury Community Area The strategy in relation to proposed increases in housing numbers is based on demographic data that, it is felt, being used in an inappropriate way. The net effect is likely to produce a general housing stock that is mis-matched to that actually Comments noted. The strategy includes policies 764 required. Specifically, the strategy indicates that 44% of affordable housing and 48% of private which seek to deliver the correct mix of housing SO3 sector housing will be for dwellings with a minimum of 3 bedrooms. The demographic date for Wiltshire’s residents. clearly indicates that single occupant units are required for young people just leaving home and also more mature residents living alone following divorce, death of a spouse etc.

Comments are noted. Chippenham along with Trowbridge and Salisbury has been identified as Chapter 2. para 2.3 refers to Salisbury, Trowbridge and Chippenham respectively as cathedral a principal settlement in the settlement strategy. city, county town and market town. This is correct and the descriptions must still apply after any These three centres are the most significant development has been completed. In particuar, Chippenham's character as a market town must settlements within Wiltshire and will be the be preserved by limiting both the amount and most importantly the rate of development. para primary focus for development. The role and 2.12 states that the amount of increase in housing in Wiltshire has increased between 1971 and Housing 765 function analysis identifies that these settlements Chippenham 2001 much more than the Southwest in general and the country as a whole. Certainly the Requirement have a number of similarities that indicate their character of Chippenham has changed dramatically since I came here in 1977. I feel that this potential to be the focus of development in rate of increase must be slowed down considerably or its character as a market town will be lost Wiltshire. These settlements can be considered to altogether and forever. para 2.19 refers to environmental quality. I fully support the need to have a regional importance, and offer the best preserve it. I trust that the challenge will be addressed in a pro-active way with determination. potential to improve self-containment and enhance the economic performance of Wiltshire. Cross Comment No. Comments Officer Comments Issue Reference By The Wilts. Core Strategy refers to Large Villages and Small Villages whereas the South Wilts. Core Strategy (published earlier) refers to Secondary Villages and Small Villages. There are diferences in the definitions given for both. Very usefully the Wilts. Core Strategy mentions employment opportunities and notes that housing developments in Large Villages should be mainly in small groups within exisiting boundaries so promoting "organic" growth. These factors are not mentioned in the definition of Secondary Village. I presume that the definitions given in The approach and definition to development at the Wilts. Core Strategy will replace those in the South Wilts. Core Strategy so that there is large and small settlements is being revised. The uniformity in policy across Wiltshire. The way new housing is distribuited in villages is I believe support for part of the policy is welcomed and the 780 crucially important and almost as important as the total numbers involved - the Wilts. Core comments regarding housing development will be Question 1 Strategy definition should avoid inappropriate "large single blocks" of new housing being added. taken into account when revising the policy. The I also note that the Wilts. Core Strategy document does not make any distinction between eventual policy on the settlement strategy will be villages in either the large or small categories. I suggest that some villages across the county amalgamated the South Wiltshire Core Strategy. may be of all". Of course adding significant numbers of houses to large or small villages does not make much sense anyway since as the document comments housing, employment, transport etc., should go together and "out-commuting" is a serious problem in Wiltshire. I suggest that additional housing in villages should be mainly limited to mainly small numbers of affordable houses that are badly needed across the county. Noted. It is a priority to ensure that brownfield Preservation of the environment against unnecessary development is my prime concern. land is used before Greenfield and the strategy 795 Ingenuity should be used to exploit existing space in built up areas rather than expanding into will aim to balance the objectives of protecting our Chapter 1. Q22 green land. The county does not need to unduly expand its population. environment with the need for new homes and jobs. This looked good. Especially when I read Chapter 1, 1.4 "Providing the most sustainable pattern of development that minimises the need to travel....". However the word sustainable seems to have been lost in translation in the actual text of the documents that follow. The word sustainable does not equal sustained. What The Core Strategy advocates is SUSTAINED building of houses and industrial units (NOT in the best locations for sustainability in its true sense) in an effort to get enough funding to sustain the ambitions of some Members to build yet Through the Core Strategy we are attempting to more road miles. I totally disagree (see comment above) that Wiltshire residents do not have a cut greenhouse gas emissions through ensuring 798 part to play in reducing our carbon footprint and reversing Man's effect on global warming. The development is located in the most sustainable Chapter 1. Q22 UK has been signed up for years to international agreements to do just that (Rio, Kyoto etc) so location and ensuring that new buildings are built even if some residents do not feel morally obliged to be responsible they are living in a country to energy efficient standards. which has committed itself to taking remedial action to tread lightly on the planet. Unfortuantely this too seems to have been paid only lip service in most sections of the Core Strategy. Wiltshire is years behind many other local authorities. Where is the innovation here? It looks very much like a repeat in a poor quality soap opera which is sad when so many people have obviously worked hard to put this together. Cross Comment No. Comments Officer Comments Issue Reference By The graphics, even in full view, are not clear. The road map is incorrect. As there are no locations on the deprivation map it makes little sense. I have been told by my Parish Council All graphics will be recreated at a higher Chair that I live in a deprived area which is absolutely hilarious. There are indeed a few resolution and to existing address issues households in the village where benefits are claimed but we are incredibly fortunate to have village shops including a post office, public houses, 3 community buildings plus church, a The deprivation data comes from the Department primary school, playing fields, good access to informal recreation areas and the Wessex of Communities and Local Government and a full Ridgeway and still hanging on a reasonable bus service to local towns and Salisbury. There is analysis is available within the Deprivation in a pretty good community spirit with leisure, education, health and sporting activities. There are Wiltshire report (available at 806 houses to rent. Many residents are self employed or work from home and therefore spend their www.intelligencenetwork.org.uk). Chapter 2. Q22 income locally. Yes, we would appreciate less potholes and more unblocked drains. Yes, the footpaths are few and far between. Yes, there is some antisocial behaviour but teenagers have The housing requirement is evidenced within to have some expression and we do lack any scout/guide group/youth club (they have been lost Topic Paper 18, which has been reviewed by an over the past 20 years). If this is deprivation then let the whole of the UK enjoy it! Wiltshire is in independent expert and found to be sound. danger of losing one of its most treasured assets - countryside. 6.000 houses in (mostly around) Trowbridge, 1,390 for Westbury, 1,770 for Warminster? Is that 37,000 new houses. For The commuting data is taken from the 2001 a population now of 456,000 can this really be justified? Where is the data that supports the Census. out-commuting theory?

As a town councillor I am concerned that the consultation has not been democratic. Even in the latter stages of the consultation i am still meeting people who are not aware that it is taking place and would certainly like to voice their opposition to the size of proposed development in Comments noted. Every effort has been made to Chippenham. Also elderly residents without internet access were told they could have a hard ensure that as many people as possible are Consultation 807 Q22 copy of the core strategy but then had problems getting hold of one and residents who were aware of the Core Strategy and have the process able to view one of the documents available to the public found they had the wrong forms to opportunity to comment on the proposals. complete when they arrived home. An document which could have such a huge effect on the future of Chippenham should be accessible to all.

Comments noted. Every effort is made to ensure This electronic format is much better than previous attempts but still not entirely user friendly. the document is readable and understandable to The graphics, especially maps, leave a lot to be desired. As others have commented most all. It is also necessary to ensure that the people will be put off by the complexity of the system, the length of the document and the document is detailed enough to withstand scrutiny Consultation 810 terminology used. Not all submitted comments seem to have loaded onto the system? The low in order to be considered sound. Once comments Q22 process numbers of comments received is of great concern. I can only hope that the majority of are submitted online they are then validated responders have used hard copy as I am aware of many people who, like myself, care deeply before they appear. Comments are also about Wiltshire and have comments to make, are not included in the 'View Comments' sections. submitted by post. These then have to be entered into the online system.

There are too many priorities. There needs to be a simpler strategy for those of us who do not work in planning to be able to understand and thus be able to make comments. Suggest. 1. Protect landscape. Our main asset. This would include environment in the local and global sense. Raise standards of environmental protection and so on. 2. Plan built environment. That would include promoting (insisting on) better standards in design and build. ALL new build to Thank you. Comment noted and the number of inlcude solar panels (on individual houses and industrial units where possible), water Strategic objectives will be rationalised in the next 811 saving/collecting/usage facilities, possibly also wind turbines on individual builds. ALL new build version. Agree, about landscape and design and Chapter 3. Q22 to include the highest standards of insulation. Simple considerations such as windows on South polices will be developed to deliver these facing elevations/enough windows to provide light and reduce use of artificial light/heat. Layout outcomes. of developments to encourage walking and cycling and discourage driving of private cars. Development adjacent to rail and bus transport. Houses/ industrial build for proven NEED not speculative building. Ask local small and medium businesses what they would require - that is where the bulk of our reliable economy lies? Houses attached to studio/workshop space? Cross Comment No. Comments Officer Comments Issue Reference By With reference to: 1.4: I quote from the document: "...ensuring full community involvement in Comments noted. Every effort has been made to planning for significant new proposals..." What methods does the Council intend to employ in ensure that as many people as possible are securing full community involvement? It has not succeeded in doing so with the present set of aware of the Core Strategy and have the documents (how could it, mounting an exhibition for only an afternoon and evening at Bridge opportunity to comment on the proposals. This House, Trowbridge, with a consultation period of about 3 weeks, and at a time of school includes via the local media, web and holidays, when many parents are away on holiday?)How does the Council propose to get consultation events. The consultation began everyone to participate? 1.16: Community Area Boards. Again I quote :"...including before the school holidays on June 13th and Consultation 824 opportunities for people to help shape the future of their local area." 1.17Another quotation: Q22 ended on 8th August. All the events were held process "...empowering local people to have a greater role in what happens in their local communities." before the school holidays and so it was felt that One notices that no predication is made in these 2 excerpts about how many people might be this gave the opportunity for as many people as involved. The forthcoming Localism Bill will be an jnteresting test of democracy. having to do a possible to comment before they went on holiday. balancing act between the monolith of the Council. the wealthy but relatively uncaring For all the strategic sites in the document, further developers, and the ordinary people. who have no real power as individuals and yet foot the masterplanning will be expected to take place to bill. It is up to the Council to devise a means of encouraging people to come and act together, if include local community. real democratic decisaions are to be made, Perhaps the Localism Bill wjll be of help.

I support the concept of protecting the open countryside, as well as retaining the uniqueness of individual settlements, both of which the Core Strategy recognises are prized objectives by the local community, and am pleased to note they are an important objective for this strategy and will be taken forward by appropriate and strong policy mechanisms. In this connection it is Agreed and we will continue to work closely with 837 Chapter 3. Q22 important to ensure that Swindon Authority's boundaries and developments should not Swindon to mitigate against this. encroach further north or west. 'Green lungs' are important not only to this Community Area, but also to Swindon itself whose own green spaces (Lydiard Park, Coate Water, etc) are already very heavily used.

Topic Paper 5; legislative context – The Water Water With reference to SO5 and SO10 we feel that abstraction from the River Kennet should be Framework The comments are noted. Additional emphasis resources; addressed more strongly and that pressure should be brought to bear on Thames Water and Directive; on the existing issues associated with water abstraction HM Government to provide resources so that other sources of water can be found for Swindon. 842 Catchment abstraction in the River Kennet will be added to issues SO10 The European Water Framework Directive should listed in the topic papers and Wiltshire Flood Topic Paper 5 to increase overall awareness of (focused on Council should play an active role in delivering the Catchment Plan for the River Kennet The Management the water resource matters. the River value of rivers as natural green corridors should be emphasised Plan; River Kennet). Basin Management Plan. Cross Comment No. Comments Officer Comments Issue Reference By Response to Wiltshire Core Strategy Consultation Document Simon Killane, Wiltshire Councillor Topic paper 17 sets out the progress made in for Malmesbury 07 th August 2011 Wiltshire is a special place with a diverse range of determining an appropriate requirement and communities. Our County boasts natural and built environments that are appreciated for their distribution of housing for Wiltshire from 2006 to history, beauty and character. While there may be a national need for more housing, there is 2026 to inform the draft Wiltshire Core Strategy. also a national need to preserve our heritage and community. Malmesbury must not be a target This process considers the strategic objectives for for developers to make short-term profits. I am not against growth. Growth must have its limits the county as well as taking into account local and any further growth must be at a pace that recognises the needs of those already living factors and aspirations for growth identified here. I request that a detailed Infrastructure Delivery Plan is a prerequisite to all of the through community consultation. Further Malmesbury housing numbers identified in the core strategy . This plan will identify the information on any phasing can be found in topic infrastructure that will be necessary to support the development proposed. Any infrastructure paper 17. delivery plan must clearly demonstrate that key services such as schools, medical centres, road An IDP will support the core strategy and identify networks, etc will be adequately supported to deal with increased population. This study should key infrastructure for the town. SO3, CP2 Housing 843 form part of our neighbourhood Plan. I strongly assert that access to good quality skilled Infrastructure needs to be delivered in line with Malmesbury SO9, CP3 Infrastructure employment must be a prerequisite to any future development proposals for Malmesbury. I development (CP3). It is recognised that there are assert that satisfying local housing and employment need must take priority over the need to infrastructure issues in Malmesbury, specifically indiscriminately expand the housing numbers in locations proposed for future development. I primary school capacity issues. Further work will request that the planning period is divided into three phases , these would be: 2006 to 2016, be carried out to resolve this issue through the 2017 to 2021 and 2022 to 2026. This would allow more appropriate balancing of housing neighbourhood planning process or another demand and infrastructure requirements with development delivery. I request that the planning mechanism. definition of "Sustainability" and "Resilience" are clarified in the consultation document. These Small sites will be allocated through either the ambiguous words are used in relation to hugely important policy proposals. Regards, Simon community led neighbourhood planning process Killane, My Website: http://simonkillane.mycouncillor.org.uk Wiltshire Councillor for or another planning mechanism in close Malmesbury, www.wiltshire.gov.uk Malmesbury Town Councillor, www.malmesbury.gov.uk consultation with the local community. Home: 01666 823169, Mobile: 07761 682103 Email: [email protected] Skype: A glossary will be included in the submission simon.killane document. I welcome both the opportunity to comment on the Wiltshire Core Strategy and many of the proposals contained within it. However, I have 4 major concerns with the paper: (i) it is too insular. Wiltshire is heavily dependent on surrounding counties for health services, education facilities etc etc. The document does not indicate how Wiltshire Council will seek to work with surrounding councils to achieve its goals. This is particularly relevant to goals relating to climate change which will require regions to work together if anything meaningful is to be achieved. (ii) it does not address the problems that currently exist. We can not simply propose that anything new meets high standards regarding sustainability and protection of the environment. Wiltshire Council must also tackle the problems that already exist. For example, the current approach to the Air Quality Management Area in Bradford-on-Avon is not acceptable and nor are the county's current flood defences. Wiltshire Council needs to address these problems as well as, not merely set out plans that suggest they will seek to avoid exacerbating these problems with Comments noted. An infrastructure delivery plan any future developments. (iii) it is not serious about tackling damage to the environment and is being developed alongside the Core Strategy. human health through the continued over-reliance on carbon fuels, inappropriate land use and Discussions with infrastructure providers who Consultation 844 Q22 inefficient use of resources. Climate Change is mentioned but when decisions are to be taken have regional interests have informed the work. process about settlement strategy and delivery of infrastructure it rather slips down the agenda. For Wiltshire does engage with neighbouring example, renewable energy sources are not deemed to be critical infrastructure - yet how else authorities. can we seriously reduce our carbon footprint without these - and Wiltshire Council suggests that as little as 35% of development will have to take place on previously developed land - land is a resource that needs to be carefully managed, not wantonly destroyed by "developments". Linked to point (ii), the strategy does nothing to address the inefficiency in terms of energy of existing buildings - Wiltshire Council should have a strategy to address our existing infrastructure as well as addressing new developments (iv) it is using the current financial difficulties the country faces to avoid addressing very beneficial and longer term but costly developments. If we are going to progress, then we have to assume that well within the next 15 years, the economic climate will have improved so that significant infrastructure developments can at least be in the planning stage if not in the implementation phase. Thus, we should be planning for such work in this document. Cross Comment No. Comments Officer Comments Issue Reference By

I would like to make general comments regarding two of the strategic objectives. Strategic objective 8: to promote sustainable forms of transport is insufficient in that it does not fully Agree - a policy is being developed (CP65) which address public transport in particular rail links for passengers and freight. This must be will prioritise the use of rail for freight. Flooding 845 addressed if Wiltshire Council is serious about tackling climate change. Strategic objective 10: Chapter 3. Q22 agreed, but new development will be also be a to minimise the risk of flooding and effective water management, must be extended to cover key mechanism to raise funds for the work. improving flood defences for existing developments and facilities and not restricted to placing requirements on new developments.

Steeple Ashton has a well documented Village Design Statement that details the village. However, over and above the considerations detailed in the VDS there is an access problem. Village Design Statements will continue to form a The roads approaching from both north and south are inferior C class roads that do not readily material consideration in planning applications. accommodate HGVs, LGVs and farm vehicles and are already busy in rush hour traffic. There Currently Steeple Ashton is listed as a Small are two difficult points for drivers, the junction at Ashton Common where the Trowbridge road Village and therefore policy does not proposed to meets the road from Hag Hill and equally the corner at the top of Common Hill which is sharp, build beyond current boundaries. However, the narrow and a difficult turn for HGVs, LGVs and farm vehicles. With regard to the above, the approach and definition of development in Parish Council requests that the following points are included as part of the Core Strategy: i) To villages is being revised. The majority of the 882 Trowbridge take into account the Steeple Ashton Village Design Statement. ii) No extension to the village issues raised in this comment would not be policy limit. iii) No further development of both businesses and dwellings, in particular large addressed by a Core Strategy and are likely to be properties that would exclude young people from living in the village. iv) To build a small the subject of a neighbourhood plan or another number of affordable housing only when proved to be necessary. v) To retain the Acreshort DPD or they would be address by a particular Lane and St. Mary's Recreation Fields as open spaces for the use of the village. vi) If development. The Council recognises the need circumstances change and Keevil airfield becomes redundant then it must revert to farm land. for maintaining strategic gaps and this will vii) Every effort should be made to preserve existing ‘Green Belt' land between Trowbridge and continue as part of the plan. any neighbouring settlements.

I object to this draft core strategy. What is proposed for employment land allocation and Noted. The Core Strategy does attempt to housing land allocation appears to be misconceived for our basically rural county. I am very address the issues raised in regards to transport much in favour of development on redundant existing sites in the towns, rather than green field but recognises that only a gradual change can be sites. It seems to me that there are ample derelict sites available. I suspect that not enough is achieved. Core Polices 42 through 48 contain being planned to reduce wasteful fuel usage and to combat damaging emissions. I fear that Number of 886 detailed transport policies which look to address Q22 some within Wiltshire Council still harbour longings for counterproductive bypasses within 'A350 Issues the issues raised. It is recognised that the associated traffic issues'. I have struggled to contend with the draft core strategy document, as document can be difficult for non-planners, much of it is not expressed in everyday language. I am an ordinary resident and do not have nevertheless the document carries legal weight the spare time to research all of the issues. I have also found the official response 'portal' off- and needs to stand up to scrutiny. putting.

It seems to me that far from giving local communities power to prevent unsuitable & countryside The Core Strategy is focused on balancing spoiling developments the new plans will make objections almost irrelevant. Also not putting competing demands and attempts to provide for brownfield sites at the core of redevelopment seems to put a nail in the coffin of sensible necessary development within environmental development. The proposals will bring no comfort to high streets, already under threat from out limits. Current and new legislation in the form of Number of 890 of town centres ,the building of which bring added traffic & building problems. Also development the Localism Bill still advocates this approach. Q22 Issues seems not to address infrastructure improvements before building takes place, this is especially Devizes is an example where due in part to true in Devizes where there is a problem not only with traffic but also services. I hope the ongoing traffic issues no sites have been council has the interest of its residents before a slavish adherence to a misguided government allocated to ensure that the development can be policy properly serviced by the correct infrastructure. Cross Comment No. Comments Officer Comments Issue Reference By Wiltshire Core Strategy – Consultation Document Response from Whiteparish Parish Council 1. The Wiltshire-wide document now reflects some of the concerns that we registered over previous drafts of the South Wilts Core strategy; e.g. deliverability in the light of public sector funding cuts, austerity measures leading to a protracted period of recession and the plight of national finances. It also reflects the need for infrastructure to be coordinated with development. There is a new dimension, resulting from ‘Localism’, with an emphasis on Neighbourhood Plans. 2. a. Employment statistics – see Figure 2.1. Why is the MOD not included as an ‘industry’? Education, Health, Transport and Public Administration are included; why not the military? b. Map 1.1 shows our area as ‘Southern’ Wiltshire. The text refers to ‘South’ Wiltshire and specifically The South Wiltshire Core Strategy (paras 1.12 and 5.14.1). We battled for South Wiltshire as opposed to Downton to define our area. Preferred is ‘South’ Wiltshire, its briefer, punchier and already exists as our area title; so why change it to ‘Southern’? c. We believe that Map 4.1 should show the New Forest National Park ‘NFNP’ boundary (which of course overlaps part of Wiltshire); it will serve to remind planners of the proximity principle when considering development. 3. The Wiltshire Core Strategy document does not directly address our area to the extent that in relation to the specific South Wiltshire area it makes direct reference to the ‘South Wiltshire Core Strategy’ document. However the Wiltshire document is the overriding document which we understand will override the South Wiltshire Core Strategy which will then in turn be incorporated into the Wiltshire Core Strategy and include the relevant more specific aspects from the South Wiltshire Core Strategy. The principles are closely Noted. Employment statistics include the MoD as aligned, focusing development predominantly on the Principal Settlements, Market Towns and public administration. The South Wiltshire Core Local Service Centres rather than large and small villages. The ‘South Wiltshire Core Strategy’ Strategy is due to be merged with the wider was subject to a recent consultation which ended in May which reflected consequential Wiltshire Core Strategy, policies will only be changes following the overall reduction in proposed housing numbers for the area from 12,400 changed or updated where necessary. The to 9,900 following the RSS numbers being disregarded. Topic Paper 20 within the South current Wiltshire Housing figures do not include Wiltshire Core Strategy identified the rationale for appropriate sustainable growth and housing 200 houses that have permission in the area strategy in the area. In tangible terms, for our specific ‘Southern Wiltshire Area’ the overall defined as west of Swindon, although it is within Number of 900 Q22 proposed numbers were reduced from 740 to 555. This is not directly addressed at all in the the Wiltshire Council boundary. This will be Issues ‘Wiltshire Core Strategy’ document since reference is just made to the separate ‘South Wiltshire rectified for the new draft. Comments about the Core strategy’. Nonetheless it would appear appropriate to respond with some comments on spatial strategy have been passed to the relevant the Wiltshire Core Strategy, not least since it will become the overriding document for our area. officer. Comments about the application of In addition, there are some interactions between the two documents upon which we comment. policies on settlement boundaries will be One such clarification is the perpetuation of boundaries within the Core Strategy, especially the consistent across Wiltshire. Finally, it is correct status of ‘Housing Restraint Areas’ and ‘Housing Policy Boundaries’. 4. Overall Housing that New Forest National Park should be properly Target - There appears a discrepancy between the total housing target of 37,000 and the referenced in the document. associated 26,900 houses identified in the Wiltshire Core Strategy Document leaving a balance required of 10,100 therefore required in the remaining areas, and the 9,900 identified in the ‘South Wiltshire Core Strategy’ as recently subject to final consultation/revision. Given the large existing allocation in South Wiltshire I presume the 200 balance will be allocated to the specific areas outlined in the ‘Wiltshire Core Strategy’ and not to South Wiltshire. Our understanding of the breakdown from the respective documents is as follows: Wiltshire Strategy A South Wiltshire B Chippenham 4,500 Trowbridge 6,000 Bradford on Avon 670 Calne 1,380 Corsham 1,200 Devizes 2,150 Malmesbury 1,200 Marlborough 850 Melksham 2,040 Pewsey 600 Tidworth 1,900 Warminster 1,770 Westbury 1,390 Wotton Bassett 1,250 Salisbury & Wilton 6,280 Amesbury 2,395 Southern Wiltshire 555 Mere 250 Tisbury 420 26,900 9,900 Total 36,800 A Breakdown per Wiltshire Core Strategy B Breakdown per South Wiltshire Core Strategy - We note the Topic Paper 20 review in January 2011 of the ‘South Wiltshire Core Strategy’ provided a detailed/robust analysis of housing needs for the South Wiltshire Area. Total Required per Wiltshire Strategy 37,000 As identified above there is a discrepancy with the two documents in this regard. As noted in Topic Paper 20, 6.5 within The South Wiltshire Core Strategy “9,900 dwellings is still ambitious as is demonstrated when compared to the historic delivery rates representing a 22%increase?”. We would therefore expect that the rest of Wiltshire to take the balance of 200 houses to meet the overall target. 5. Core Policy 1 – Settlement Strategy We would fully support the proposed Cross Comment No. Comments Officer Comments Issue Reference By settlement strategy outlined in Core Policy 1. The primary focus of development should be on the principal settlements of Chippenham, Trowbridge and Salisbury. The Market Towns should be the next focus and then the Local Service Centres. We agree that consistent with the rural nature of most of Wiltshire only limited development should take place within the large and small villages, commensurate with allowing some sustainable growth. The majority of such development should be within the existing boundaries and local communities should be involved through neighbourhood plans. 6. New Forest National Park - Whilst reference is made to the New Forest National Park in the introduction of the core strategy paper it is neglected elsewhere in the consultation document. The New Forest is an important part of considerations in a number of factors, both in terms of development and protection of historic and rural areas and consideration should be given to giving this greater prominence and explicit reference in the Core Policies within the Wiltshire Core Strategy document. In the ‘South Wiltshire Core Strategy’ it was an important factor in the deliberations and final document and we consider that this should be an equally reflected in the Wiltshire Core Strategy since it is a prominent part of South Wiltshire Community Area with some villages either completely or in part the New Forest National Park. 7. It is important to fully understand the interaction between the ‘Wiltshire Core Strategy’ and the ‘South Wiltshire Core Strategy’. We presume that the Core Policy 1 terms in relation to ‘Principal Settlements’, ‘Market Towns’, ‘Local Service Centres’ and ‘Large and Small Villages’ will have the same meaning as the equivalent term used in the ‘South Wiltshire Core Strategy’ document e.g. ‘secondary villages’ equating to ‘large villages’. 8. We note in 4.11 in respect to large or small villages that ‘initial development will be supported in order to help retain the vitality of those communities’. We would support this as long as it does remains limited. 4.11 goes on to say ‘Development of large villages will predominantly take place within existing settlement boundaries and take the form of small housing and employment sites. Some development adjacent to boundaries will be acceptable, as long as it has been identified through the appropriate mechanism and development in conjunction with the local community. Development of large villages will meet the housing needs of the local community and where possible safeguard the existing facilities and employment’. We would emphasise the importance of local involvement in any such considerations and fully support the point made in 4.13 that ‘development must be in character with the scale and appearance of the settlement’. Modest growth must be balanced with maintaining the distinctive rural characteristics and nature of villages in Wiltshire, hence why we fully support the focus of development in the Principal Settlements, Market Towns and Local Serves Centres outlined in Core Policy 1. Whilst reference is made in Core Policy 25 for rural diversification and enterprise, the existing restrictions on agriculture buildings being retained for such use should be maintained as proposed in particular it should be clearer that change of use from agricultural buildings use to residential will not be allowed. 9. Existing housing boundaries - 4.15 of the strategy document states that for ‘Principal Settlements, Market Towns, Local Service Centres and Large Villages settlement boundaries, as defined by former District Local Plans, will be retained’. This would seem a sensible approach subject to any revision in the context of community led Neighbourhood Plans. However it is important to understand how this interacts with the most recent ‘South Wiltshire Core Strategy’ revisions where Para 5.3, page 39,F) now states ‘To reflect this any Housing Policy Boundary (HPB) for settlements not listed on paragraphs (A) to (E) and all Housing Restraint (HRA) and Special Restraint Areas (SRAs) currently within the Local Plan will be subject to a further review in connection with the Wiltshire Core Strategy – where the degree of sustainability of such settlements will be considered on a consistent countywide basis. Until such time as this review is undertaken the HPBs, HRAs and the SRAs will remain in place’. To what extent has the Wiltshire Core Strategy directly considered this and the review now been completed? In particular are HRAs (where any development is not normally allowed) or SRAs to be retained when the Wiltshire Core strategy is adopted. For example will the existing Housing Restraint Areas be retained or just returned to open countryside which would seem more appropriate. Clarity around this issue would be appreciated particularly in the South Wiltshire area where such designation is currently applied as it uncertain how this would apply in the future. More generally it would be helpful to Cross Comment No. Comments Officer Comments Issue Reference By understand how a county wide ‘Local Plan’ will be developed for specific planning consideration which presumably will supercede the extant Local Plan.

The issues within Trowbridge have been noted within the Community Area strategy. These result There is no historical background to explain why Wiltshire is as it is now. Trowbridge is an from a set of circumstances, largely led by the unattractive town and a disgrace as the county town, and has been like this for years. Why is 903 economy. Plans are being developed for the Chapter 2. Q22 this? What has been attempted to rectify the situation? Why have these attempts failed? What regeneration of the town through the has been learned to make the core strategy work? Transforming Trowbridge project. This will run in parallel with the Core Strategy. Where are the financial parameters? Strategic plans made without financial boundaries you Overall 905 Noted. Q22 are likely to end up as Rolls Royce plans with Ford Focus finance. Strategy Demographic Change We strongly support Wiltshire's aim of providing appropriate 909 The support is noted Chapter 2. Q22 accommodation to meet the need of the ageing population including extra care housing. Spatial vision We believe the Spatial Vision should acknowledge that the supply of affordable Agree. This is what SO3 means when it says housing and the range of care and accommodation options for older people will have greatly providing everyone with access to a decent 911 Chapter 3. Q22 increased. This is particularly as the Council has identified the need for affordable housing as a affordable home and specific policies are being ‘key challenge'. produced to deliver just that. OBJECTION TO THE PROPOSED WILTS CORE STRATEGY WILTSHIRE COUNCIL'S SLY WAY OF PUTTING IT ACROSS There are undue amounts of misleading presentation, slanted phrasing and spin. Windy and ambiguous wording has been an observed unfair trait of Wiltshire Council. The intent seems to be to make it hard to comment on and to leave interpretation Noted. Every effort is made to provide a legible open. The public relations jargon and planning-speak, in writing intended for Wiltshire residents, and sound document. Nevertheless, the is difficult to understand or to stomach. For example, the buzz-word ‘footprint' is featured in two document carries legal weight and must stand up completely different contexts in WC's highly-paid chief executive's short foreword. Inappropriate to scrutiny. Topic papers 17 and 8 set out the repetition of words from elsewhere is mediocre. What about plain English? The Glossary of housing and employment requirements Terms at the back of this document does not appear to explain ‘footprint', ‘robust', ‘vision' or the respectively and also set out the reasons for other words used out of their original context. WC's chief executive says that a ‘test' of WC's Number of 926 Q1, 2 & 3 development to focus along the A350 corridor. Q22 Core Strategy is whether it is ‘deliverable'. This could be more intelligibly (or intelligently) Issues While it is noted that development will bring worded as whether it is likely to be workable and productive. WILTSHIRE COUNCIL'S CORE increased levels of traffic, Core Polices 42 – 47 STRATEGY CONTRADICTIONS The proposed core strategy document acknowledges that set a comprehensive transport strategy that looks Wiltshire is basically rural. People like homes near to countryside, though most Wiltshire to provide a gradual change and ensure residents travel elsewhere to their work-places. A fundamental problem is the widespread habit sustainable transport options, i.e. walking and of motor-car use. Wiltshire Council envisages more of this and hopes to urbanise Wiltshire, cycling are included in all new development. many think. Wiltshire Council's ‘vision' is of yet more housing and business on the edges of the towns; urban advances into our countryside, linked to (and helping to fund) WC's ‘improved A350 from the M4 to the south'. After the total failure of WC's eastern Westbury Bypass project (which intended a new road through our countryside in order to open it up to development) it is Cross Comment No. Comments Officer Comments Issue Reference By observed that similar defective proposals are still being promoted by a core inner few. An example of misleading presentation (for I do not have free time to point to all of them) is in showing the A350 as if it is an existing strategic transport route to the south coast. This was pointed out in previous ‘consultation', but WC's misleading map still appears. WC's curious explanation of Sustainable Development in its glossary of terms indicates that WC has struggled with the basic contradiction of putting these two words together. I think that Wiltshire Council's proposed Core Strategy would spoil our Wilts countryside for no worthwhile reason. Inept, counter-productive and divisive, or, in other words, daft. EXAMPLE OF OBVIOUS WAYS OF ENCOURAGING SUSTAINABLE JOURNEYS Misuse of motor-cars for short journeys, or car journeys which can be avoided altogether, is presently sadly observable. This altogether disastrous bad habit has to be changed. A logical solution is to greatly improve conditions for low-emission/low-energy transport. As a Wiltshire resident for years, I am deeply disappointed by WC's attitude to railways. We now need to genuinely bring about much more walking and cycling for short journeys and to get on to travelling on trains. WC's Wilts Core Strategy is very lightweight on this. Safety is the most common reason given for going short distances by car. It may indeed be a cop-out excuse. It is also a genuine concern for many when the hazards of walking and cycling are considered, or are frighteningly experienced. It needs specific proposals. There are many ways in which safety for walkers and pedal-cyclists could be improved: o 10-20mph speed limits through towns and on narrow twisty country lanes. Low limits would make no real difference to average journey times, but can make it safer for all. o Provide genuine joined-up dedicated cycle ways, not worse than useless little pieces. o No adults cycling on pavements and pedestrian crossings, by notices & enforcement. o Run a recurrent campaign to educate motor vehicle drivers of their prime responsibility for the lives of walkers and pedal-cyclists (who are alleviating fumes and congestion). o Turn around the thinking that walkers and cyclists always give way to motor vehicles. Under many circumstances, it is difficult and dangerous for a cyclist to stop quickly. o Provide secure stowage (not just open racks) for bicycles, in towns and at stations, at no cost to the users, which would prevent bicycle parts being removed by thieves. o Discourage car-reliant attendance at primary schools distant from children's homes. o Replace stiles in the countryside with swing gates (that can be used by all walkers). o Repair potholes and fill in crevasses (which are dangerous for cyclists) in roads. o Avoid/remove road narrowing obstructions which are hazardous for cyclists. This is a simple example of a useful strategy which could be practically implemented. WC's proposed strategy relates sustainable transport and energy use to development, which is not right. It has only vague empty words about sustainable travelling in general. SUSTAINABLE DEVELOPMENT...? Here is a big example of sly play with words strung together out of their original context. Development means more new homes, mega-sheds and roads. This is not sustainable. There is no justification for Wiltshire to have more development on present green fields. There is no need. There is no high unemployment here. There are old redundant sites awaiting re-use. There are areas of genuine employment need in other parts of Britain, where supporting services are already in place. The strategy for Wiltshire should be to preserve our natural environment and to reduce the damage caused by burning-off fuel. Cross Comment No. Comments Officer Comments Issue Reference By The notes below are explored further in our main submission available as a separate document Comments noted. Chippenham along with The Showell Protection Group has serious concerns over the current public consultation Trowbridge and Salisbury has been identified as process on the Draft Core Strategy with regard to Chippenham. It is felt that information a principal settlement in the settlement strategy. provided has been misleading, contradictory and completely opaque to the vast majority of lay These three centres are the most significant people and elected members. This seriously calls into question the validity of key aspects of the settlements within Wiltshire and will be the process. The Council is to be applauded for holding a second round of public consultation on primary focus for development. The role and proposals for Chippenham following widespread concerns within the community following the function analysis identifies that these settlements first round of consultation. It is recognised that this was not a statutory consultation, but a wish have a number of similarities that indicate their to engage with the public on proposed plans. However, the process appears to have been potential to be the focus of development in flawed and to have caused significant confusion which may well have influenced the scope and Wiltshire. These settlements can be considered to nature of the feedback received. This section identifies the main concerns of the Showell offer the best potential to improve self- Protection Group. a) Question 5 on the Core policy for Chippenham states ‘ Core policy 5 containment and enhance the economic includes two options for the location of future growth in Chippenham. Please indicate which performance of Wiltshire. As set out in the strategic option you would support and explain why’ . This would clearly indicate that comments document and in the evidence contained in are requested only on the two options proposed. It is understood that this was exactly the Housing Requirement Topic Paper the proposed interpretation placed in the question by the Planning Committee of Chippenham Town Council level of homes is considered reasonable as it in formulating their response. Discussion on other options was not allowed to be considered at supports jobs growth in line with that across the Planning Meeting and a proposed amendment offering a third option was ruled out of order. Wiltshire and will not lead to the exacerbation of b) The above interpretation does however appear to be in direct contradiction with the opening out-commuting levels. This is in response to a paragraph of Draft topic paper 14: Site Selection Process, June 2011, which states ‘1.1 It is specific issue that Chippenham has a net-outflow important to note that the site selection process is ongoing and it will continue to evolve as new of commuters and future development should evidence comes forward, including the responses to the latest stage of public consultation’ The redress this. Question 5 is not misleading. As wording of Question 5 therefore appears misleading. c) Much has been made of the fact that stated at paragraph 1.18 of the document, the there has been several major face to face consultation exercises, including the ATLAS Core Strategy will be based on robust evidence facilitated workshop and the Chippenham Vision Board public meeting. However, at no time about the challenges facing Wiltshire and the during these meetings were the current Option 1 and 2 put forward for discussion. All of the most realistic ways of meeting those challenges. Housing formal discussion related to the merits of the four original options, not the current ones. Much This current consultation provides a further 932 Requirement; Chippenham has been made of the ‘public view’ expressed at these meetings in supporting the current opportunity for the local community and other Site Selection proposals, but there was, in fact, little reference to the current options. d) The current proposals stakeholders to help shape the Core Strategy. appear, in part, to arise from a rejection of earlier options. There has been no opportunity for Two events were held as part of the additional public discussion of the current proposals other than one very well attended public meeting in consultation work for Chippenham in September the Lacock Village Hall called, not by the planning team, but by one of the Council’s elected 2010 and March 2011. Reports are available as members. In passing, it is noted that the overall mood of this meeting was to reject both of the part of the evidence base. It is incorrect to say currently proposed options. e) The sheer complexity of the consultation documents make it that the discussions related to the merits of the 4 virtually impossible for a layperson (or elected member!) to comment from an informed position. original options, not the current ones. Options This is particularly unfortunate in the new climate of ‘localism’, where members of the public are were not presented at either event. Information encouraged to play a greater part in determining the future of their community. Such used included the land promoted by landowners, involvement requires people to be well informed with access to information in an easily developers and agents at Chippenham for accessible format. It is of little surprise that so few people (including elected members) have consideration for allocation through the core read all of the main consultation document given it runs to nearly 200 pages, let alone the 20/30 strategy process. The two options presented in supporting/historic documents. Information could well have been presented in a more coherent the consultation document and justification were format with better indexing of supporting documents. f) Core information has been presented as prepared after the second workshop enabling ‘facts’ whereas it is often data that is open to interpretation. For example it has been claimed information from the consultation events and that there is large scale out-commuting from Chippenham. This may be the case, but the ‘facts’ other evidence to be taken into account. The are based on the 2001 national census, now 10 years out of date. Furthermore, as is identified arrangements for consultation for the Core later in the Showell Protection Group response, this data is directly contradicted by at least two Strategy were approved by Cabinet and included other Council sponsored technical reports that claim Chippenham is ‘self contained’ (see notes holding exhibitions in various locations around on ‘Out-commuting’ in our full submission). g) It is recognised that attempts were made to Wiltshire such as Chippenham. It is incorrect to inform local people of proposals particularly by the holding of a series of local exhibitions. At the assume that low numbers of people attending time of writing it is not known how many people attended the exhibitions, but from the events can be attributed to the style and content observation of several of these events the numbers were low. This would suggest there were of material. This is not the first time consultation issues with both the style and content of the promotional material for these events. h) Where for the Core Strategy has taken place and may local activists encouraged attendance, as happened with the Lacock public meeting, (where have led to consultation fatigue. Also, not all three independent groups promoted the meeting), over 150 people attended with many more proposals are controversial. These factors are Cross Comment No. Comments Officer Comments Issue Reference By unable to get into the meeting. i) The omission of any reference to the more likely to have influenced the numbers of Showell/Patterdown/Hunters Moon development from the proposals on the Corsham people attending events. The proposals for South Community Area plans has caused considerable confusion. There is anecdotal evidence that West Area of Search were not shown in the local Corsham people having, understandably, only read the Corsham Community Area section Corsham Community Area section. Agree to of the proposals were totally unaware of the large scale developments proposed in the amend map 5.10 in future. .Evidence collected so Community Area. j) Further, references to ‘Lacock’ in the Corsham Community Area section far has not suggested the proposals for make specific reference to there being no major development activity associated with the Chippenham will have a detrimental effect on village. k) The incorrect map for Option 1 in the consultation documents for Chippenham is Lacock's natural surroundings. Lacock Village is most unfortunate as it presents a misleading picture of the proposal. Once this was pointed out recognised as having buildings of architectural to the spatial planning team by the Showell Protection Group, an errata message was inserted merit and being an important tourist destination in on the consultation site, but not in the Chippenham section! The erroneous map of has the Corsham Community Area section. It is felt remained throughout the consultation. This added an unnecessary level of further confusion to that although the proposal for an area of search the process. l) There have been repeated calls by the Local Authority officers and members for south west of Chippenham includes land within contributors to provide ‘evidence’ in their submission. It is, of course, nearly impossible for the the administrative boundary of Lacock Parish, it layperson to offer technical evidence on issues such as the impact of development on will not have a detrimental impact on those infrastructure, the environment, etc. What they are able to provide is their opinions/aspirations factors. We have tried to make the consultation on issues such as the visual impact of developments or concerns about traffic or access to information easily accessible on the website. schools etc. Repeated comments by officers seem to classify this as not being ‘evidence’, but However, we accept that there is always room for ‘nimbyism’ with little credibility. It will always be the case that feedback from laypersons will be improvement. In terms of the complexity of the at a subjective level. This does not devalue it in any way. If local Government wishes to engage documents, it is difficult to overcome this because more meaningfully with its electorate then public opinion must be taken into account in a it necessary to prepare robust evidence which will credible manner. m) The ‘Supporting Documents’ tab on the main consultation site makes no be subject to scrutiny and challenge at the reference to the numerous Topic Papers that underpin the draft proposals. n) The fact that Inquiry. The 2001 census has been referred to. Options 1 and 2 have only comparatively recently been proposed has meant that there has However it is recognised that it is ten years out of been no opportunity for many agencies to comment on these proposals in a format that can be date and where possible alternative sources of fed back to others to comment on. It will be interesting to see how many responses are statistical information have been used. It is not received from such agencies to the new proposals. o) There is some confusion over what sites agreed that the issue relating to out-commuting is can be considered as part of the strategic planning exercise. In repeated public presentations contradicted by other documents. The extract officers of the Council have stated that only sites ‘put forward’ or ‘promoted’ can be considered. from the North Wiltshire Issues and Options This would seem to be at odds with guidance provided in the ‘Strategic Sites, Background document relates to data from the 2001 census, paper October 2009 section 4.9’ where it is stated that the initial list of sites considered were as does the South West Observatory report obtained from the following sources: Sites allocated for housing in each previous district’s Local whereby they both say that 49-50% of residents plan which are partly or fully unimplemented National Land Use Database returns Previous live and work in Chippenham. You have referred Urban Capacity Studies Inspection of OS base maps and aerial photographs Officer knowledge to the Interim Roger Tyms Report. The final Sites identified through consultation exercises by the previous district councils A ‘call for sites’ version of this report differs in that it states at exercise from both the former districts who carried out the SHLAA This guidance would seem to paragraph 7.10 that 'there are also towns where indicate that where consultation respondents were unhappy with either Option 1 or 2 they are at the working population is greater than the number liberty to offer alternative suggestions. This was however not clear in the guidance provided in employed in the town. These are the main 'out- the public consultation. p) The draft consultation document repeatedly makes reference to the commuting' settlements. Chippenham is listed as housing requirement being determined through a comprehensive review ‘involving local 1 of 7 settlements. Later in the document, it is communities’ and ‘reflecting local people’s aspirations’ . In reality the proposals appear to have recognised at paragraph 7.42 that Chippenham is far more to do with the stated ‘assessment of the political aspirations of the Council’ Factual only 49% self-contained and that it is a net inaccuracies relating to Showell Farm Current data relating to Showell Farm appear confused. exporter of employment with strong travel to work The site is identified in the Draft Core Strategy as being 28.85 hectares of available land. In patterns experienced with Bath, Bristol and other previous discussions and public enquiries the site is stated as being 25 hectares (ref public towns including Swindon. Interrelationships were inquiry 1999). The Wiltshire Employment Land Study identifies Showell Farm as being in the examined and the conclusion is that Chippenham ownership of ‘Lackham’. This is incorrect, a significant minority of the site is owned by the has a dominant employment role as an Telling family, the current owners and residents of the Showell Farmhouse. A further small employment centre, but that its functionality parcel of the land is owned by the Pierce family. In several recent public consultations it has appears to be strongly influenced by the M4 and it been stated by the planners that 8 hectares of the site would not be used for development, but is partly a dormitory town. These issues alongside would be used for ‘landscaping’. No explanation has been given for this quantum, but is it others have all been reflected in the Core supposed that this would include the required buffer around the three listed building of the Strategy and it is not agreed that the recession Showell Farm and the nearby archaeological site. It is understood that, in 2007, as part of their will have dramatically changed this position. The site investigation in the Rowden Lane/railway embankment area, Redcliffe Homes planning application for Showell Farm related to Cross Comment No. Comments Officer Comments Issue Reference By commissioned two assessments of land contamination from Robson Liddle Ltd (consulting that site only. It has been recognised in the core engineers) and Wessex Water. Both reports indicated significant contamination levels that strategy that the site on its own is divorced from would require considerable remedial work before the land could be used. It is further the town and therefore it is proposed that it forms understood that some of this contamination was judged as associated with the railway line part of a high quality sustainable urban extension usage. If correct then it is reasonable to surmise that the land adjacent to the railway to Chippenham, which will be fully integrated with embankment on the boundary of Showell Farm is likewise contaminated thus further reducing the town and town centre. The site selection the availability of land. There is anecdotal evidence that the rearing of pigs was moved from this process set out in Site Selection Topic Paper has area due to contamination fears. The issue of contamination will require further investigation. taken into consideration the environmental The cumulative effect of the above is that the site would appear to have a usable area very constraints. The options do not promote significantly lower that the estimated 28.85 hectares. This begs the question ‘how much land is development in the flood zones. A surface water actually needed?’ Conclusion Taken together, this catalogue of errors, omissions and management plan is being prepared for complexity, leaves Wiltshire Council open to a formal challenge on the validity of the Chippenham and all strategic sites will include consultation process. References Applications called in under section 77 of the town and appropriate SUDs. The SW area of search and country planning act 1990: For development by Crest Nicholson Properties Ltd and Hygrade east Chippenham site include a GI Foods Ltd; at Showell Farm, Chippenham, Wiltshire. Applications APP/J3910/V/99/000028/P2 corridor/country park in and around the river and 000029/P2; 1999 Wiltshire 2026; Planning for Wiltshire’s future; Strategic sites; corridor. This is to ensure development avoids the Background paper 2009 Housing requirement technical paper: Technical paper setting out the floodplain, but also is in recognition that the housing requirements for Wiltshire 2006-2026. 1.3, 1.10.d Bristol River Avon County Wildlife Site is an important wildlife corridor and there is the opportunity for this to maintained and enhanced as part of any GI proposals. As explained in Site Selection Topic Paper, national planning policy advises that where significant development of agricultural land is unavoidable, LPAs should seek to use areas of poorer quality land grades 3b, 4, and 5 in preference to that of higher quality, except where this will be inconsistent with other sustainability objectives. Chippenham along with Trowbridge and Salisbury has been identified as a principal settlement in the settlement strategy. These three centres are the most significant settlements within Wiltshire and will be the primary focus for development. The strategic sites will provide an opportunity to strengthen the employment offer of the town and to provide a mix of dwellings types including starter homes; key worker dwellings and executive style homes. This will help to safeguard and enhance Chippenhams role as a principal settlement, will strengthen its role as a business location and ensures people can live and work locally, including young people. It is considered that these reasons justify the loss of agricultural land, in accordance with the national policy guidance. Work is ongoing to ensure that strategic sites in the Core Strategy are available and deliverable. The consultation process hasn't been flawed. Evidence to support the core strategy is contained within the topic papers. The evidence is being revisited and updated where appropriate to ensure that the Core Strategy will be a sound document. Cross Comment No. Comments Officer Comments Issue Reference By The notes below are explored further in our main submission available as a separate document The Showell Protection Group supports the concept of a strategic plan for managing the growth of growth of Chippenham to become a vibrant festival/market town. New housing will be Comment noted. The work undertaken by DTZ required to accommodate changing demographics and employment opportunities will be identified that less intensive development should needed to provide jobs for local people. The Showell Protection Group does not however be spread across the 7 market towns of accept the need for Chippenham to be classified as one of three ‘Principal Settlements’ in Amesbury, Calne, Devizes, Melksham, Wiltshire where growth is targeted over and above the needs of the local population. Such a Warminster, Westbury and Wootton Bassett with designation is a political decision on the part of Wiltshire Council, not based on economic or the main settlements of Salisbury, Chippenham social needs. Furthermore the decision is in direct contradiction with one of the main technical and Trowbridge taking a greater share of reports (DTZ Wiltshire Workspace and Employment Land Strategy, Final Strategy Document, 939 employment growth. It identified up to 39 ha for SO1 August 2009) commissioned by the Council that recommended less intensive development Chippenham as well as 73 ha across the 7 should be spread over seven main towns in Wiltshire. In our full submission we point out the market towns. The workspace strategy will be inconsistencies in the current proposals and, in particular, the Showell Protection Group will updated over the summer and this new evidence argue: The current proposals are based on out-commuting data that is significantly out of date will be used to direct the final employment quanta and contradicted by other studies The proposal to allocate approximately 90% of the proposed and allocations across Wiltshire and take account strategic land allocation to Showell Farm is misguided and will not best serve the business of more recent events such as the global development of Chippenham There needs to be a more creative approach to the use of recession. brownfield sites and previously allocated land The location of large scale housing to the south west of Chippenham will not support the much needed regeneration of the town centre; rather it will damage it Wiltshire Liberal Democrat response to the Wiltshire Core Strategy Consultation Document 07 th August 2011 Wiltshire is a special place with a diverse range of communities. Our County boasts natural and built environments that are appreciated for their history, beauty and character. While there may be a national need for more housing, there is also a national need to preserve our heritage and community. Wiltshire must not be a target for developers to make short-term profits. We are not against growth. Growth must have its limits and any further growth must be at a pace that recognises the needs of those already living here. We request that ALL communities are allowed to have a real say in the choice of strategic sites of new housing and commercial development. The proposed strategy only allows this opportunity for Market Towns. We believe that any community wishing to create a neighbourhood plan, as defined by the Localism Bill, should be able to propose the most appropriate sites for development. We request that the core strategy clearly states that all Wiltshire communities will have the opportunity to propose their preferred locations for any future development under the neighbourhood planning proposals detailed in the Localism Bill. We request that a detailed Noted. The Council will develop the process and Infrastructure Delivery Plan is a prerequisite to all of the proposed developments identified in geography of Neighbourhood Plans in line with the core strategy major development proposals . This plan will identify the infrastructure that will Localism Bill. It is the expectation that all levels of be necessary to support the development proposed. Any infrastructure delivery plan must Number of 942 community will have the ability to develop Q22 clearly demonstrate that key services such as schools, medical centres, road networks, etc will Issues Neighbourhood Plans as they see fit. The be adequately supported to deal with increased population. We strongly assert that access to comments regarding clarity in the glossary are good quality skilled employment must a prerequisite to any future development proposals. We noted and these will be taken into account. assert that satisfying local housing and employment need must take priority over the need to indiscriminately expand the housing numbers in locations proposed for future development. We request that the planning period is divided into three phases , these would be: 2006 to 2016, 2017 to 2021 and 2022 to 2026. This would allow more appropriate balancing of housing demand and infrastructure requirements with development delivery. We request that the definition of "Sustainability" and "Resilience" are clarified in the consultation document. These words are used in relation to hugely important policy proposals and so should be clearly defined. We request that the definition of "Community" is clearly defined in this document . The town and parish and community area boundaries, as referred to in the draft documents, does not adequately reflect the population and resource utilization in these areas. It fails to adequately account for the importance of service catchments. Resource boundaries are far more important than political boundaries when considering future development proposals! Written on behalf of Wiltshire Liberal Democrat Councillors by: Simon Killane, Wiltshire Councillor for Malmesbury, 07 th August 2011 Cross Comment No. Comments Officer Comments Issue Reference By This vague long winded document is uncosted, unfunded, delusional, out of date and relies too much on 'should' and 'hope'. There is a distinct absence of the word 'how'. Far and away the main emphasis is on what appears to be a wildly overstated demand for subsidised social housing. The mathematics are somewhat dubious, as indeed is any idea of how to pay for this. It is somewhat disingenuous to categorise military housing as 'private letting', when obvously it is being provided by the tax-payer. In addition the figure of '300,000 properties in Wiltshire empty for more than 6 months', is surely a typographical error. According to the Treasury's figures there are 740,000 properties in England that fall into this bracket. It seems unlikely that about 40% of the national total is in Wiltshire. In '8.30' and '5.12' of the 'Economy' section, it states that 'it is the desire is to see employment development lead ANY future housing growth'. Why has this commitment apparently been abandoned? By using the coalition's Community Minister Andrew Stunnel's New Homes Bonus to renovate unused properties, the outstanding housing waiting list in Wiltshire can be more than adequately housed, without the need to build any new taxpayer owned properties at all. Merchant Venturers offer to sell land adjacent to London Road in Devizes for 400 dwellings, has the same basic flaw as their failed application to constuct a large pensioner's complex adjacent to the same road. This would add in excess of 2,000 vehicle movements a day attempting to join a road that struggles to cope already. This appears to be in direct conflict with Wiltshire Council's obligations to comply with European Air The Core Strategy recognises that local Pollution regulations, compliance with Carbon Neutrality and reduction of road traffic. In employment opportunities can be improved and addition, of course, is the ongoing failure to provide sufficient local public spaces. The increase looks to provide land and facilities to attract in the aged demographic in Wiltshire is, in part, because they do not need access to employers of higher skilled jobs and businesses. employment. If the quality and income of employment was raised in Wiltshire, property would Many of the issues mentioned are being be relatively more affordable, and residents would not need to commute for better paid work. addressed, for example high speed broadband. With rising inflationary pressures, how long before residents who commute out of the area for There is no focus on Devizes as compared to better paid work move away to be closer to their employment? All these worthy intentions Marlborough and both are expected to develop in require funding. So in turning to the 'Economics' section we hope to find solutions. With the line with the settlement strategy and the individual exception of mostly Swindon (bizarrely hardly mentioned anywhere in the Consultation Overall 998 SO1 targets that have been set with regard to their Q22 Document), opportunities for well paid employment in Wiltshire is distinctly limited. Mention is Strategy current and future roles in Wiltshire. It is unclear made of Wiltshire's over dependence on the public sector providing jobs. Since 2008 the where the statements regarding Military housing economy has changed. From 2011 a lot of these jobs will go, not to return for the forseeable and empty properties appear both are incorrect. future. There appears to be little evidence by the creators of this document of interest, or However due to the complex nature of military understanding, of the requirements of commerce to provide and retain well paid long term housing some of it is counted as private letting, employment. Much emphasis is made of Salisbury, Trowbridge and Chippenham as Strategic however this only applies to a small amount of Centres of Employment, so why so much pressure on Devizes? Marlborough is excluded, why? properties that are being built under new financial As access to the M4 and London is deemed to of prime importance, it is closer to a motorway arrangements that have come in over the last few junction than Calne, Devizes, Melksham, Trowbridge, Warminster and Westbury, which like years. 90% of Wiltshire has poor access to the M4. This has been exacerbated by the wilful failure to implement the 1991 National Plan which would have included a motorway link from Junction 17 of the M4 to an extended M27. All we provided with on the A350 is an incomplete single carriageway bypass at Chippenham and, partially around, Melksham. There is no mention of any commitment to bring the A303, A342 or A360 to anything approaching the standards found elsewhere in Europe, let alone our competitors throughout the U.K. 'Visit Wiltshire' identifies tourism as a potential source of increased employment. If so, why are the Tourist Offices being shut? Increasing the price and scope of car parking in Wiltshire towns will encourage people to drive to retail parks in places where parking is free, such as Cribbs Causeway in Somerset. Bioscience has a limited history in Wiltshire and with the closure of Porton Down, even less. ICT has a diminishing profile in Wiltshire with the closure in recent years of 2 Motorola plants, Lucent, Nokia and Philips. Even the multi-employment call centres are vacating the county. Warehousing and disrtibution provide a relatively small number of lower income jobs. With the combination of underinvested and inadequte road infrastructure, along with a shrinking economy, the existing enterprises, mostly around Swindon, are probably adequate. So where are the students graduating from our good Wiltshire schools in the near future to find well paid and satisfying employment? Probably not in this county as things stand. So they will not be needing housing here then? An investment in high speed communications and a positive policy Cross Comment No. Comments Officer Comments Issue Reference By to attract companies to establish viable businesses in Wiltshire is essential. Employ vision, ambition and investment to make Wiltshire the place where people want to work and live. Ask yourselves, how you are going to secure those 25,750 jobs you have targeted.

Yes, firstly I would like to comment in general on Wiltshire Council's house building policy. I feel the policy puts far too much emphasis on developing green field sites when brown field sites within towns (especially Trowbridge) remain undeveloped and an eye-sore. Brown field sites should present the major area of development for four reasons: - They already have much of the infra structure surrounding them that is required eg roads, sewerage, electricity etc - Many people who would like to buy a new house also want to be near new and modern conveniences of a large town (also cuts commuting, pollution and carbon emissions down) - Brown field sites need to be developed to keep the town alive and looking respectable. - The green fields, hedgerows, woods and villages that surround us are what define our community within Wiltshire - urban sprawl is not ! And it will not bring tourists or investors either. Secondly, I would like to Comments noted. The strategy includes a target comment on the position of Hilperton as an individual village. There seems to be a large and to deliver at least 35% of new homes on 999 worrying inconsistency about Hilperton's status. Previously at the general election Hilperton previously developed land. Changes to the Question 2 was said not to be part of Trowbridge so the residents voted in the Chippenham constituency. settlement strategy to define Hilperton as a large So, Hilperton is separate from Trowbridge - that is a 'large village' - in fact the MP for village will be explored. Chippenham (Duncan Hames) refers to Hilperton as a Village within his constituency. However, when referring to the map of the Trowbridge area Hilperton is no longer listed as a 'Large Village'. Why is this ? Also what protection is afforded to Hilperton's 'Large Village' Status ? It is recognised that Hilperton is a village and has an historic core, therefore, this needs to be protected by re-instating its correct status as a 'Large Village' within your policy document. In summary and in general, I believe Wiltshire and Trowbridge will be best served by the redevelopment of areas already within the town to make it a real prestige place to live, visit, work and shop in. Hilperton should be re-instated as a 'Large Village' within your document. Best regards, Francis Morrissey Comments noted. Strategic objective 5 aims to Core Policy 46: Demand management include electricity generation To help the Council to meet enhance the vitality and viability of town centres any sustainability targets shoppers need to be encouraged to use their local shops and town thus offering people the opportunity to shop in centre shops, rather than the out-of-town retailers. The inequality of free car parks for out of SO8 their local centres rather than elsewhere. Town centres 1008 SO8 town shoppers and car parking charges to use town centre car parks needs to be addressed. SO7 Car parking charges may be a theme that can be Transport Core Policy 48: Strategic transport network The "promoted and encouraged" words for the re- addressed through the neighbourhood planning opening of Corsham railway station are not strong enough. process. Comment regarding core policy 48 noted. Cross Comment No. Comments Officer Comments Issue Reference By General comment on the Draft National Planning Policy Framework On 25 July 2011, the government published a Draft National Planning Policy Framework which “introduces a strong presumption in favour of sustainable development” (p.8, consultation document). We are deeply concerned that the Government is putting the economic aims of the planning system ahead of its environmental commitments. It means that documents such as the Wiltshire Core Strategy are even more crucial: “Where [development] plans are not up-to-date, or do not provide a clear basis for decisions, the policy establishes the clear presumption that permission should be granted, provided there is no overriding conflict with the National Planning Policy Framework as a whole” (p.9). This strong pro-economic growth focus raises serious concerns for us that the ongoing restoration of the natural environment could be hindered. Given that the Draft National Planning Policy Framework was published after the publication of the draft Core Strategy, we strongly suggest that the Core Strategy be carefully reviewed to ensure that it provides a clear The Council will ensure that the Core Strategy is basis for decisions in line with the strategic objectives, particularly to protect and enhance the compliant with the NPPF and the new Localism 1012 natural environment and to address climate change. The Strategy must also be regularly NPPF Q22 Bill as and when these documents develop. It will updated in response to a rapidly changing policy and legislative framework. For example, if the also need to take into account all new legislation. Biodiversity Action Plan (BAP) process changes or is replaced, then the Core Strategy must be written in such a way as to remain current or be updated to reflect changes. In particular, County Wildlife Sites are at risk as they are not a statutory designation such as Sites of Special Scientific Interest (SSSIs). The only form of protection afforded to County Wildlife Sites, of which there are 1,552 in Wiltshire, has been through the planning system.It is crucial, therefore, that these sites and other aspects of the natural environment are clearly safeguarded in the Core Strategy and other parts of the Local Development Framework. These sites play a critical conservation role by providing wildlife refuges, acting as stepping stones, corridors and buffer zones to link and protect other designated sites. Together with statutory protected areas, they support locally, and often nationally, threatened species and habitats. County Wildlife Sites represent the minimum habitat in need of protection in order to maintain current levels of wildlife.

Wiltshire needs a visionary approach to the future. This is just more of the same, which has left declining town centres, traffic congestion and the council paying lip-service to "sustainability" Where are the targets, such as emissions targets, to meet climate change? Despite asking for Noted. Every effort is made to make it easy for hard copies of the appendices over four weeks ago, these have not been received. It is not Overall 1013 respondents. These comments will be taken into Q22 easy reading the many documents electronically, especially when trying to cross refer. They are Approach account not available in libraries. This has been a very difficult exercise to complete on-line. For example, in hard copy these comments were at the very end of the document, as Q 22, and yet on-line it comes at the start!

We welcome the emphasis on tackling climate change and protecting and enhancing the 1014 environment, as well as the broader commitment to sustainable development, outlined Support Noted Q22 throughout chapters 2 and 3. Cross Comment No. Comments Officer Comments Issue Reference By Strategic objective 1: to deliver a thriving economy which provides a range of job opportunities We feel that more could be done to integrate the overarching priority on tackling climate change into this strategic objective. Although expansion of green jobs is mentioned as a key outcome, we believe that the Core Strategy should aim to ensure that a thriving economy is also a green economy. In June 2011, the government published a new White Paper on the natural environment, The Natural Choice , which aims to use the National Ecosystem Assessment (NEA) and other evidence to develop a green economy which captures the value of nature and contributes to improving nature. The White Paper also includes plans to establish new Local Nature Partnerships (LNPs). Wiltshire’s Core Strategy should be designed to support any LNPs established in Wiltshire and to encourage LNPs to work closely in collaboration with the Swindon and Wiltshire Local Enterprise Partnership (LEP) to develop a green economy in the county. We suggest that an ecosystem assessment for Wiltshire to mirror the NEA would allow for local natural capital to be defined and valued, would inform decision making and would help identify barriers and opportunities for green business growth. Strategic objective 2: to address climate change We welcome this objective and many of the key outcomes. However, we believe that some of the outcomes could be strengthened to help deliver the strategic objective. For example, a key outcome under strategic objective 3 is that “All developments will have been low-carbon or zero-carbon”; this could also be incorporated into a key outcome for strategic outcome 2. We welcome the key outcome that “New developments will have incorporated appropriate adaptation and mitigation for climate change”. Undertaking a local ecosystem assessment (as suggested above) might assist in developing natural solutions to adaptation and mitigation challenges, e.g. flood alleviation and support for sustainable urban drainage. We would also like to see the final key outcome on waste management strengthened to reflect the recent Government Waste Review for England, for example: “New development will have contributed to achieving a zero waste economy, including by incorporating facilities to reduce, Agree that it is important that all steps are taken reuse and recycle waste. Strategic objective 5: to protect and enhance the natural environment to ensure development addresses the issue of We welcome this objective and many of the key outcomes. We would like to suggest an climate change. Policies are being developed to 1017 Chapter 3. Q22 amendment to the introductory phrase “The reuse of Wiltshire’s limited amount of previously attempt to do just this and are outlined in Chapter developed land should be maximized”. Draft topic paper 5 for the Core Strategy recognises that 6. LNP's will be considered as the Core Strategy previously developed land (PDL) can be exceptionally important for wildlife (pp.30-31), comes to implementation. referencing Planning Policy Statement 9. The UK Biodiversity Action Plan (BAP) includes “Open Mosaic Habitats on Previously Developed Land” as a UK Priority Habitat and this is reflected in the Built Environment Habitat Action Plan for Wiltshire. PDL is also of functional importance in that it provides areas of early/pioneer habitat and general refugia within otherwise impoverished landscape areas. As a habitat, PDL is at substantial risk and subject to destruction and serious degradation from factors including urban development. We suggest that the phrase be amended to: “The reuse of Wiltshire’s limited amount of previously developed land should be maximized while protecting any significant biodiversity or geological interest”. The first key outcome states: “Where possible, development will be directed away from our most sensitive and valuable natural assets, towards less sensitive locations.” We would expect the most sensitive and valuable natural assets to be protected from development in all circumstances and many are already protected by law. It is also unclear how “sensitive and valuable” assets or locations are defined. We therefore suggest that this outcome be strengthened and clarified to help deliver the strategic objective. We welcome the commitment in the second key outcome to protect habitats and species from inappropriate development in accordance with the Wiltshire BAP. As noted in draft topic paper 5, this has not been the case to date (p.31) and we urge Wiltshire Council to ensure that the final Core Strategy provides clear and robust policy to protect priority habitats and species and to encourage development that contributes to extending and enhancing biodiversity. In the penultimate key outcome, “european” should be capitalised. We would like to see an additional key outcome to strengthen this objective overall in the light of the White Paper on the natural environment and Making Space for Nature , the review on which much of the White Paper is based. The plans contained in the Core Strategy will have a huge impact on ecological networks in Wiltshire and must contribute overall to restoring and enhancing those networks, working at a landscape scale. In Cross Comment No. Comments Officer Comments Issue Reference By order to achieve this, we need a greater understanding of the condition and value of natural capital in Wiltshire, which could be achieved through an ecosystem assessment to mirror the NEA, as mentioned above. This would provide a sound context and evidence base for implementing the vision of sustainable development contained in the Core Strategy. Strategic objective 9: to ensure that infrastructure is in place to support our communities We are concerned that different types of infrastructure are prioritised, as we consider that any infrastructure required to make new development sustainable should be considered essential. If this is not the case, then the Core Strategy will have failed in its aim to ensure sustainable development. We consider the provision of open space and green infrastructure to be an essential part of any new development, if it does not already exist to satisfactory standards. This is recognised in draft topic paper 13 for the Core Strategy as well as Planning Policy Statement 12. The critical nature of ecological networks is recognised in the White Paper on the natural environment and in developed areas these networks are fragile and in need of protection, which can be provided through green infrastructure. We suggest that the Core Strategy be amended to recognise that green infrastructure is an essential part of sustainable development. Strategic objective 10: to minimise the risk of flooding We suggest that this strategic objective be reworded as follows: to minimise the risk of flooding of properties. Sustainable land management can help to minimise the risk of flooding of properties and natural floodplains and other green infrastructure in developed areas is a vital part of this. Enhancing the natural function of floodplains will increase flooding in floodplains and decrease flooding in urban areas. An ecosystems assessment approach can help to understand and value the role of green infrastructure in flood risk alleviation and its contribution to sustainable development. These comments are the views of Holt Parish Council on the Wiltshire Core Strategy Consultation Document. Chapter 1 - Introduction Holt PC support the need for the Core 1020 Strategy and intend to propose a Neighbourhood Plan for the Village in due course. There are, Support noted. Chapter 1. Q22 however, concerns over the lack of resources to support the production of a comprehensive plan.

Improvements needed to the way the consultation is carried out and the way the web version Consultation 1044 Comments noted. Q22 operates, eg why is this question hidden away in the 'glossary of terms' section? process

Comments noted. Every effort was made to ensure that topic papers were available online as A credible Core Strategy would have been developed from thoroughly researched options part of the consultation. The Core Strategy which had been publicly available. In this case it was noteworthy that a large number of the process is an iterative process. Evidence Consultation 1048 topic papers were missing at the start of the consultation period on 13.6.2011 (only 4 out of 18 gathering in ongoing throughout and therefore it Q22 process being present) and others have been added in piecemeal fashion throughout the consultation is appropriate for further changes and period. amendments to be made to the Core Strategy proposals in light of new evidence set out in the topic papers including consultation feedback. Cross Comment No. Comments Officer Comments Issue Reference By

CCAN notes that consultation with interested residents from the community area has taken place with the public exhibitions in Corsham and Lacock and a well supported public meeting in Lacock which represented the concerns of the Lacock community in particular. It is disappointing that in the introduction to the Core Strategy it is not made clear that the plans for Chippenham have significant overspill from the Chippenham Community Area and that Comments noted. It is acknowledged that the Corsham residents in particular should make reference to both the Corsham and Chippenham Corsham Community area section did not include sections. Any development to the South West of Chippenham would have an impact on the reference to the SW area of search. Agree that Site Selection; 1050 Chippenham Corsham area and residents should be made fully aware and consulted to consider all of the this will be included on map 5.10 in future. Parish Lacock implications on local infrastructure. Under separate and important agendas the role and position and community area boundaries are not a matter of the Community Area boundaries are increasingly presented as being important for service that can be considered in the Core Strategy. provision and funding decisions yet in the case of rural planning it appears that the boundaries and impacts on the infrastructure within those boundaries is not part of the consideration. The Core Strategy should be seen to support the community area boundaries and to encourage the position and role of the community areas within the planning and development process.

Wiltshire Council is working with Natural England and Bath and North East Somerset Council to We have reviewed the documents and believe that the Core Strategy has not adequately produce a guidance document for planners and demonstrated that it will not have a likely significant effect on the Bath and Bradford on Avon developers to ensure that development within SAC, and the River Avon SAC. Natural England's advice is that the Wiltshire Core Strategy is 4km of the SAC would not have a significant SACs and thus not legally compliant, and is currently unsound. We are also concerned that the Council 1073 effects upon the integrity of the site. A Landscape designated SO5 has not demonstrated that it has adequately considered the impacts on designated landscapes Assessment will be undertaken to appraise the landscapes in writing its policies. As a result it has not discharged its duties to have regard for the capacity of the strategic site options to purposes for which the AONBs were designated, nor justified the rationale for its policies, and accommodate landscape and visual change, and that the policies may be unsound . this will inform the pre-submission draft core strategy.

Strategic objective 5. Paragraph 3.5 says "...The reuse of Wiltshire's limited amount of previously developed land should be maximised...". It should be noted that Brownfield sites can be important habitats (in some cases a UK BAP priority habitat - Open Mosaic Habitats on Agree. The SO is a desired outcome not a Previously Developed Land), and in these situations, reuse should not necessarily be planning condition, which should be most 1074 maximised. An alternative wording might be "The reuse of Wiltshire's limited amount of effectively be incorporated in policy. Chapter 6 Chapter 3. Q22 previously developed land should be maximised unless of high environmental value..." For contains polices on Biodiversity which will achieve more information on this subject, see exactly those controls. http://www.buglife.org.uk/Resources/Buglife/Planning%20for%20Brownfield%20Biodiversity.pdf

Cross Comment No. Comments Officer Comments Issue Reference By Habitats Regulations Assessment Natural England has a number of concerns with respect to the conclusions of the Habitats Regulations Assessment. Bath and Bradford on Avon SAC 1. Wiltshire Council is in the process of producing 1. The conclusion states: The Draft Core Strategy physical damage to sites and supporting this guidance document in collaboration with habitats as an issue where bats are the qualifying feature and while it is not addressed in the Natural England and BNES Council. 2. Corsham thematic policies it is considered in relevant Community Areas. It is also understood that policy has been amended to reflect the presence additional guidance will be provided by the Council in a Supplementary Planning Document on of the SAC. 3 & 4. These allocated sites are this issue. It can therefore be concluded that the Core Strategy will not give rise to significant being masterplanned in accordance with advice adverse effects on European sites. 2. The Corsham policy makes no reference to the SAC. 3. from a local NE representative 5. The guidance While the Bradford on Avon, and Trowbridge policies do refer to the SAC, there is no (this is unlikely to form an SPD in itself) is demonstration that the allocated sites can be delivered without having a likely significant effect required to ensure that developers and planners on the SAC whether or not a SPD is produced. 4. It should be noted that by virtue of the close are fully aware of the potential sensitivities of the proximity of the Bradford on Avon to a bat roost which may well be part of the SAC meta area and requirements in order to pass an population, there are a range of vectors by which the site could affect the SAC. 5. It is not clear appropriate assessment where necessary. why the provision of a SPD is necessary. If it is necessary, the parameters for the SPD are too Without this guidance non-compliant development vague to provide certainty. If it is not necessary, it should be omitted as a relevant measure to could be passed and inappropriate applications address this issue. 6. We consequently advise that these three policies are unsound on the are likely to be received, frustrating the planning basis that they are potentially undeliverable/not in line with the Habitats Regulations. River SACs, system. 6. Policies have been amended and are Avon SAC 7. The conclusion states: Issues relating to potential effects on water quality Phosphates, 1112 now considered sound. 7 & 8. This issue is SO5 associated with development in the Warminster Community Area have been addressed by Porton Down currently only relevant to development Policies 45 and 46. It can therefore be concluded that the Core Strategy will not give rise to SPA discharging to the Warminster STW. CP69 would significant adverse effects on the River Avon SAC; 8. It should be noted that this is an issue not capture this issue in the event that it arises limited to Warminster Community Area, but a catchment wide issue. It is thus unclear why it is elsewhere in the catchment. 9. Issues relating to mentioned solely for Warminster, especially as there is a catchment wide policy. 9. Please see phosphate have been further discussed with NE / also comments under CP51 with respect to Phosphate levels and the Avon SAC. 10. As EA since this draft was issued, and the policy Natural England has advised the Council in previous consultations, road verge erosion from amended to reflect those discussions. 10. elevated traffic levels within the catchment may be having a significant effect on sediment levels Wiltshire Council has had regard to NE's within the Avon SAC. We advise that the impact of the Core Strategy on this aspect of the SAC comments in this and other consultations it was should be assessed (including South Wiltshire sites). Porton Down SPA 11. We note that all confirmed in the HRA's for the SWCS and LTP3 the policies intended to address potential impacts on N2K sites in South Wiltshire Core Strategy that the effects of road verge erosion would be have been picked up in the Wiltshire Core Strategy except Core Policy 12 (Porton Down), in addressed through normal road maintenance. which there is a requirement to produce a Wildlife Management Plan for the site. It is not clear NE has agreed that effects from the CS how this policy will be retained when the Wiltshire Core Strategy is adopted. We also note that development would be de minimise. 11. This since this was included in the Proposed submission document, in July 2009, there has been policy has been included in the pre-submission little if any progress in creating the Wildlife Management Plan. As a result, we feel less draft. confident about the deliverability of this policy. In order to ensure that this policy is deliverable, we would welcome reassurances from Wiltshire Council that the plan will be progressed.

Draft Topic paper 14 - Site Selection process The details of the site selection process are provided in the "Wiltshire 2026 Strategic Sites Background Paper (October 2009)". As we responded at the time, we advise that it has not been demonstrated that the impacts on AONBs Building on existing work further detailed has been adequately assessed and considered. For example, the only detail provided with assessment of the landscape impact, particular respect to justifying the preferred option for Warminster is "The Cranborne Chase and West Natural 1118 SO5 on AONBS, of the proposed strategic sites is Site Selection Wiltshire Downs Area of Outstanding Natural Beauty is located to the west of the option. The environment being carried out. It will form part of topic paper impact on the setting of this would need to be assessed but careful masterplanning and design 14. would protect this." The SA of the Wiltshire 2026 provides no additional detail, but advises that "More detailed assessment required to assess degree of effect and value of mitigation needed". It is disappointing that this has not been undertaken to date. Cross Comment No. Comments Officer Comments Issue Reference By

Sustainability Appraisal The SA analysis between different site allocations was undertaken in detail in the Wiltshire 2026 consultation, and the SA associated with the current consultation 1120 Noted SA SA does not add significantly to this analysis. We appreciate that the SA of non spatial policy options is difficult, and have no detailed comments to make on this.

Whilst we generally applaud the concept of a core strategy (CS) we are concerned that it is confused by its use of inappropriate terminology. The CS gets off to a poor start, even in the first line of the Foreword, when it states that ".. .we need a plan..." and then in the fourth line. It says "... this plan is the Wiltshire Core Strategy..." A plan is not a strategy and a strategy is not a plan. It is essential that authors of this CS use terms in their universal meanings and if they wish to assign new and unusual definitions to common terms, then they should be firmly explained and defined, which they are not. It is disappointing therefore that even the Forward sets the wrong tone. Another general remark is that this core strategy confines itself simply to spatial planning. Essentially, it is just about delivering new jobs and new homes. It is Noted. The Council will ensure that the Core disappointing therefore that, while its remit is not to discuss wider issues of concern it could Strategy is compliant with the NPPF and the new Overall 1127 have made reference to all the other factors that will decide whether this core strategy will Q22 Localism Bill as and when these documents Strategy succeed or fail. Of course, this strategy is already out of alignment with government, thinking. develop. With the emergence of the National Planning Framework, it is clear that the CS will need some adjustments. Finally, in our opening remarks, we note that we reserve the right to make further changes or amendments to our comments following the publication of the Localism Bill later this year and in the light of the emerging National Planning Framework. We also bring to the authors' attention is that we wish to make further comments as supporting evidence for the CS becomes available. We note there is substantial information that is missing or incomplete. Therefore remarks below can only be considered as an interim response, pending full disclosure of the council's information and intentions. Amendment required Do not refer to the strategy as a plan Realign with National Planning Framework Paragraph 1.3 : The strategy talks about strengthening communities, and increasing the supply Many good and interesting points are made here, of jobs. Speaking specifically of Purton, it is not clear if the Wiltshire Council or its predecessor however the respondent appears somewhat ever created a single job in Purton during the last twenty years. In fact the public sector's job is confused as to the actual scope of a Core not really to create jobs per se . That is the job of the private sector. Arguably the public sector, Strategy and mentions a number of items (such Wiltshire Council, should focus on its own jobs in its own organisation rather than worry about as favouring local firms for Council contracts) jobs in the outside world. The role of the public sector, such as Wiltshire Council, in terms of which are beyond the scope of any Core Purton, is to create the environment that supports job creation by the private sector. For Strategy. There instance, requirements for jobs that cannot be created by the private sector are: superfast seems to be considerable confusion on the part of broadband, good transport links, good roads, good recycling facilities and so on. Amendment the respondent as to what the Core Strategy required Make it clearer that the community strategy can only facilitate jobs and their actual means in terms of employment policy. As is creation is with the private sector Paragraph 1.4 : The strategy falls into the usual trap of correctly noted, this is a matter principally for the prefixing many intentions with the word "sustainable" without defining what this panacea is. It Private Sector,. What the Core Strategy is is simply not acceptable to say sustainable pattern of development, sustainable transport, concerned with however is ensuring an adequate Sustainability / Wootton 1128 sustainable construction and so on without definition or further elaboration. There is reference supply OF LAND to meet these needs. And this it Role of Core Bassett to the delivery of neighbourhood plans, there is no clear, unequivocal guidance on what does. The Strategy constitutes a neighbourhood plan. This clarity is due to arrive through the final stages of the response also contains an academic argument as Localism Bill. Until that Bill is quite clear on what the neighbourhood plan will look like it is to the meaning of 'Sustainability'. This is a term in premature to have neighbourhood plans as a key ingredient of the core strategy, particularly as common use, and most people now have a they appear, currently, to only be a spatial planning tool. In times gone by we used to say build generally good idea of what it means. Additionally communities not merely houses and, currently, the neighbourhood plan appears to default to the Core Strategy is required to be brief and this building just houses and not communities. Amendment required Desist from using the word must be borne in mind when one is tempted to "sustainable" unless it is specifically defined within the context of its specific use Paragraph 1.5 explain every point. In fact Sustainability as a : The vision for Wiltshire is laudable and can be supported. Given that the Wiltshire core term is defined in various Council documents, strategy is a spatial planning tool. It is not clear how it can set out a " flexible and realistic including the Sustainability Appraisal. framework". There is far more to building resilient communities than simply deciding where Regarding Neighbourhood plans, the response homes should go. Of course, where people live determines many other things. But when contains a number of misconceptions and planning where people should live, those "other things" should be taken into account at that inaccuracies. The Core Strategy has to take Cross Comment No. Comments Officer Comments Issue Reference By time of deciding where people will live, not later. Amendment required Be clearer on the account of this new and impending planning difference between building homes and building communities Paragraph 1.6 : It is far from clear system as it would be irresponsible not to do so. It what the emerging Localism Bill will say about neighbourhood plans. Consequently, this section would also be anti-democratic since the Council needs to reflect the current level of uncertainty. Amendment required Be clearer on the level of wishes to maximise understanding of and uncertainty concerning the concept of the neighbourhood plan Paragraph 1.7 : It is participation in the new planning regime disappointing that it continues to repeat the objectives of the Wiltshire Community Plan without by the community. Providing detailed guidance recognising the shortfalls of that Plan. For instance, it is now very clear throughout government however would not be appropriate in a core and by informed opinion throughout the country that, in addition to climate change, population strategy and in any event is impossible as very growth and diminishing resources are equally critical and of great concern. Amendment little has yet been published by central required Update the Wiltshire Community Plan to reflect equal priority with population growth Government . and diminishing resources. Update this strategy with two further objectives: Raise awareness of The evidence base is considered to be extremely the problems of population growth Raise awareness of the problems of diminishing resources robust and is published to the extent possible, as Paragraph 1.9 : The solution for job growth and meeting the needs of business is not always research is on-going. about ensuring that new land is identified. Although new land may be required, it is not a priority and should not be the first on the list of things to achieve. We do agree that there should be emphasis on the substantial redevelopment of outdated premises. Amendment required Emphasise that substantial redevelopment of outdated premises is far more important than the allocation of new land. Create a business panel to inform and advise Wiltshire Council on what businesses require. This panel should only have on it those who run businesses, large and small, and therefore know what is required Paragraph 1.10 : It is correct that the strategy for resilient communities should recognise that the economy has to be boosted to achieve a greater level of self containment. Therefore, there should be far more effort on raising awareness within settlements of how the economy of a settlement works. For instance, many complain that shops, post offices etc close yet continue to shop in out-of-town shopping centres. There is no or little recognition that there is a relationship between shopping outside of the settlement and the ability of shops within the settlement to survive. There is a similar relationship between the economic situation within a settlement and the need to travel to work. Amendment required Raise awareness within a settlement of how the economics of the settlement work Work to revitalise or maintain in-settlement businesses Encourage the use of local businesses to support the procurement requirements of Wiltshire Council ~ currently this is woefully poor Paragraph 1.18 : It says that the core strategy is based on robust evidence and that this evidence has been gathered from a wide variety of sources, including a community consultation. We are not convinced that this has been the case and find little actual evidence, historically, of how comments by communities are taken on board. If one looks at the sustainability appraisal that supports the core strategy you find that consultation with communities and responding to that takes the form of how to dismiss or argue against nearly every community comment. Whilst it is clear that not every community comment can be taken on board, one gets a clear sense, looking at the tables of responses and comments to a consultation, that the council's position is one of defending the Council's view to the death before finally having to make a concession to their received wisdom. There is a real sense of fatigue concerning consultation with Wiltshire Council. Simple examples include the lack of enforcement against planning breaches and the allowing of rights of way to become overgrown. In both of these cases, Wiltshire Council has a statutory obligation to deliver. When local communities represented by their parish councils, make representations to the Council concerning the above two issues there is a real lack of adequate response by the Council. Amendment required A clear statement that Wiltshire Council is genuinely committed to consultation and to act upon those outcomes An apology within the Core Strategy recognising that Council has failed to live up to that commitment, to date Paragraph 1.19 : Given that several draft topic papers are not yet available, some of which are absolutely key to the strategy we reserve the right to comment fully on all aspects of the core strategy after 8 August 2011. Amendment required Clear statement by Wiltshire Council in its core strategy that all matters relating to the core strategy may be commented upon and taken into account after 8 August 2011 until two months after the publication of all topic papers Cross Comment No. Comments Officer Comments Issue Reference By Each community area and settlement is We have a general comment on this chapter. We think that this chapter should be completely addressed within the Community area strategies 1129 revised and that there should be a paragraph concerning each settlement cross-referenced to Chapter 2. Q22 and each heading is addressed in the subsequent each of the headings of this chapter. Amendment required Revised chapter accordingly policies.

We have a general comment on this chapter. We think that this chapter should be completely revised and that there should be recognition, within the vision, of the issues of population growth and diminishing resources. There are three big issues facing the UK and this county in the 21 st century: climate change, population growth, and diminishing resources. Relevant government documents from the Foresight Committee, concerning these challenges, have been sent to Wiltshire Council last year by Ps and Qs. Following on from that, the strategic The Chapter will be reviewed as the next step. objectives should then be revised accordingly. We make a specific comment on climate There is a strong possibility that the number of 1131 change paragraph 3.5. It is true that local authorities are uniquely placed to act on climate SO's may be condensed to provide a more clear Chapter 3. Q22 change but they are also uniquely placed to act on population issues and also diminishing and punchy message. Agree that the challenges resources. Indeed, if they do not then the future will be severely compromised. We would also are key. note that the emphasis on new developments being able to address many of these issues, whilst being true, is only half the story. The existing housing within the county should also be upgraded in order to meet the same challenges. We will comment further on this chapter in the future when there is a complete complement of topic papers available Amendment required Revised chapter accordingly

Chapter 6 : We comment on this chapter generally. Until the strategic objectives can be upgraded with the additions of population growth and diminishing resources, we believe that it Overall 1134 Noted. Q22 is premature to discuss, in any detail, core policies to deliver these objectives. Amendment Strategy required Revised chapter accordingly (see previous responses as to what to include)

The duty to conserve and enhance nationally important Areas of Outstanding Natural Beauty is considerably more than the provision of Green Infrastructure. The spatial vision should, the AONB recommends, be amended to include specific reference to safeguarding, conserving, and enhancing the AONBs. It may be appropriate to mention within the Core Strategy that the CROW Act 2000 and its subsequent arrangements mean that the nationally important and nationally designated landscapes of AONBs are locally managed, with 75% of the resources for that management provided by central government sources. Therefore, in addition to having duties for these nationally important landscapes the local communities are provided with funds to ensure that local knowledge and skills contribute to the local management of these nationally special areas. The relationship between the six Key Challenges and the ten Strategic Objectives is not obvious and could be much more clearly structured. Indeed, some of these strategic objectives appear either to limit the Objective or to include separate issues within a Noted, agree. Specific policies are being single Objective. We would recommend that Objective 5 be expanded to include not just the produced that will make specific reference to the 1146 natural environment but also heritage and landscape. The Strategic Objective 6 could, with AONB. This section refers to objectives and Chapter 3. Q22 benefit, be separated into an objective to promote high quality design and a separate objective outcomes being sought. Controls should properly to safeguard the historic environment and encourage beneficial uses of heritage structures. The be set out within the aforementioned policy. Strategic Objective 9 seems a little confused in that the provision of infrastructure to support communities seems to be a prerequisite for the existence of those communities. The wording of Strategic Objective 10 seems to be missing a key word; I therefore recommend inserting 'maximise' between 'and' and 'effective water management'. The nature of AONBs means that populations are not necessarily able to access readily the services that are key features of larger settlements. The AONB would, therefore, strongly suggest that in paragraph 3.4 'High quality education services' should be supplemented by the addition 'of work place training'. Furthermore we are aware that Ministry of Defence land includes extensive holdings and that the simple statement 'brought within the overall pattern of development' could be both misunderstood and confusing. The larger training areas constitute significant areas of landscape and therefore a development might not be appropriate on many MOD locations that Cross Comment No. Comments Officer Comments Issue Reference By might be declared redundant. Without the insertion of caveats relating to the conservation and protection of natural beauty the AONB is very concerned that 'green jobs', along with some of the outcomes within paragraph 3.5 relating to climate change, could lead to inappropriate developments and activities that generate additional travel. In paragraph 3.6 it seems rather strange that there is specific reference to 'Western Wiltshire Green Belt' and no reference to the AONBs. Whilst the Strategic Objective is laudable we strongly recommend that this is presented in the context of the national significance of the AONBs. As I have already indicated, the AONBs are particularly concerned about the loss of community facilities within the villages of our AONB and we would, therefore, wish to see achievable ways of retaining these facilities. Moving to paragraph 3.8 it is regrettable that there is no mention of natural beauty and the AONBs whatsoever. There also seems to be a limitation of Green Infrastructure to sites that are publicly accessible and with wildlife value, whereas the original concept promoted by government included a much more holistic, landscape based, concept. Such a concept would, of course, be of considerable relevance to a rural county such as Wiltshire, and the AONB recommends that a more holistic concept of Green Infrastructure is adopted. I question whether, in key outcomes, agricultural soil quality can be improved through planning policies and planning actions. It also appears as though another key word has been omitted in connection with water abstraction and that the key outcome should read 'the adverse environmental effects of water abstraction will have been reduced'. Regarding high quality design and the historic environment (which, as I have already mentioned, could be separated into two objectives) there seems to be an especially hopeful use of words in the third bullet point. There 'exceptional' could, as seems to have been intended, mean high quality, whereas it could be exceptionally bad! Similarly in paragraph 3.10, first sentence, the reference to 'convenient locations throughout Wiltshire' could be misinterpreted as providing a clear steer that major supermarkets would be welcomed everywhere. Strategic Objective 8, paragraph 3.11, seem to have inbuilt conflicts in relation to improving the opportunities to use public transport when the major thrust of the Core Strategy seems to be seeking to discourage commuting. Nevertheless, from the point of view of this AONB, we would like to see the opportunity to use public transport being enhanced and that the railways that already cross the AONB should be more readily accessible to residents and visitors alike. We are acutely aware that one of the railways, the Salisbury to Warminster line, does not stop within the AONB and consequently brings no benefit to the AONB. Standard of living, has been missed and it is recommended that the document refocuses on quality of life and quality of the environment issues. In that context it is somewhat disappointing to see that paragraph 1.7 omits quality of environment from over-arching priorities. The Vision seems to be somewhat short in its focus in that paragraph 1.9 seems to be very heavily coloured by the current national economic situation, rather than taking a more positive and longer term view to 2026. Nevertheless the focus on local jobs is appreciated by the AONB. However we are concerned that this does not come through clearly in other parts of the document. Furthermore the proposed government changes to the planning system may, in the Concern noted. Para 1.7 highlights the overall case of AONBs in particular, militate against the retention of employment sites and buildings at objectives of the community plan that the Core the expense of their conversion to residential uses and the associated outward travel, and Strategy aims to deliver. Beyond the spatial travel congestion, to jobs elsewhere. Although it is noted in paragraph 1.11 that the AONB expression of the community plan the Core 1149 Chapter 1. Q22 Management Plans have been consulted for the Core Strategy there is no explanation or strategy will also ensure that our environment guidance on the way that AONB Management Plans should be considered, with their national here in Wiltshire is protected and where possible weight, in relation to locally prepared Neighbourhood Plans. Looking at Map 1.1 it is clear that enhanced, this includes landscape and the majority of the community areas include, or are wholly within, Areas of Outstanding Natural biodiversity. Beauty. The AONB, therefore, recommends that there should be very clear guidance, which is not currently obvious, as to how those parts of the community areas will be handled in policy terms differently from areas of countryside that are not of national importance. From the experience of this AONB I should also comment that the part of the Amesbury Community Area that is within the Wylye Valley between Fisherton de la Mere and Great Wishford has greater landscape and environmental similarities to the Wilton area, and is more closely associated to it, than the rest of the Amesbury area. Cross Comment No. Comments Officer Comments Issue Reference By The opportunity to provide a realistic and meaningful spatial portrait has been missed. The AONB would strongly advise that key aspects of the topography, geology and geo- morphological structure should be described to inform and aid understanding of the planning policies. The AONB is also concerned that there seem to be inconsistencies between the classification of transport routes as shown on maps 2.1 and 4.1 and the key diagram found in around the Waste Sites Allocations Consultation document. The key diagram (4.1) of the Core Strategy shows the A350 as a strategic transport route whereas the key diagram in the Waste Sites Allocations Consultation document shows the A350 north of the A303 as a strategic route but not a strategic one south of that point. Clearly the AONB has been fairly relaxed about the A350 as not being identified as a strategic route but we would be concerned if policy The Wiltshire Local Transport Plan identifies the documents start to indicate it as a strategic route with all of the implications of heavy vehicles, A350 south of the A303 as a Principal Route. This and increased numbers encroaching upon, and taking short cuts through, the AONB. is the evidence that has been used in the Furthermore, the transportation study for North and North East Dorset recently carried out by development of the Core Strategy. Dorset County Council indicates that the A350 is not a strategic route and the AONB would greatly appreciate explicit clarification of the situation. The AONB recognises the cross border The intended abolition of the RSS, as well as the relationships identified in paragraphs 2.7 and 2.8 as we also experience a high level of outward intended NPPF and removal of existing Planning commuting for jobs. We would, subject to realistic safeguards relating to conserving and Policy Statements have been carefully considered enhancing landscape, endorse the sentiments in those two paragraphs. The six Key in the development of the Core Strategy. It will be 1150 Chapter 2. Q22 Challenges set out on page 16 do not mention the key challenge that has bedevilled planning ensured that sufficient policies are included to for the last few years, and appears to be about to do so for the coming few years, which is the address any policy gaps at the regional and continuing change by central government to the principles, as well as the fine detail, of the national level. However, it is imperative that established planning systems. There is, furthermore, the prospect of a huge policy vacuum Wiltshire progresses the Core Strategy in order to when the Regional Spatial Strategy is, as government has declared, abolished. The current maintain the plan led system. This will be Wiltshire Core Strategy appears to rely to a very considerable extent on the policies of the RSS enhanced by the progression of neighbourhood being in existence. It is particularly worrying from the environmental point of view that the widely plans, ensuring that localities, in liaison with supported environmental policies of the RSS will no longer exist and the policies within the partners can ensure that appropriate Core Strategy do not appear to be sufficiently specific, robust, or detailed to prevent a policy development occurs at the right time and location. vacuum. This is of great concern as the Core Strategy is planned to be the main policy document right through until 2026. It may not, therefore, surprise you to hear that the Core Strategy document as currently drafted appears to be a mixture of policies similar to those found in the days of Structure Plans that rely on Neighbourhood Plans to flesh things out, and policies from Local Plans that assume the existence of higher level, regional, strategies. However, it looks very likely that those higher level, regional, policies will soon cease to exist. The AONB strongly recommends that the key challenges be reinforced by the insertion of reference to a challenge to conserve and enhance the natural beauty of nationally important AONBs that constitute a substantial proportion of the County. Natural Beauty is considerably more than the provision of Green Infrastructure. The spatial vision should, the AONB recommends, be amended to include specific reference to safeguarding, conserving, and enhancing the AONBs. It may be appropriate to mention within the Core Strategy that the CROW Act 2000 and its subsequent arrangements mean that the nationally important and nationally designated landscapes of AONBs are locally managed, with 75% of the resources for that management provided by central government sources. Therefore, in addition to having duties for these nationally important landscapes the local communities are Noted, agree. Specific policies are being provided with funds to ensure that local knowledge and skills contribute to the local produced that will make specific reference to the management of these nationally special areas. The relationship between the six Key 1151 AONB. This section refers to objectives and Chapter 3. Q22 Challenges and the ten Strategic Objectives is not obvious and could be much more clearly outcomes being sought. Controls should properly structured. Indeed, some of these strategic objectives appear either to limit the Objective or to be set out within the aforementioned policy. include separate issues within a single Objective. We would recommend that Objective 5 be expanded to include not just the natural environment but also heritage and landscape. The Strategic Objective 6 could, with benefit, be separated into an objective to promote high quality design and a separate objective to safeguard the historic environment and encourage beneficial uses of heritage structures. The Strategic Objective 9 seems a little confused in that the provision of infrastructure to support communities seems to be a prerequisite for the existence of those communities. The wording of Strategic Objective 10 seems to be missing a key word; I Cross Comment No. Comments Officer Comments Issue Reference By therefore recommend inserting 'maximise' between 'and' and 'effective water management'. The nature of AONBs means that populations are not necessarily able to access readily the services that are key features of larger settlements. The AONB WOUld, therefore, strongly suggest that in paragraph 3.4 'High quality education services' should be supplemented by the addition 'of work place training'. Furthermore we are aware that Ministry of Defence land includes extensive holdings and that the simple statement 'brought within the overall pattern of development' could be both misunderstood and confusing. The larger training areas constitute significant areas of landscape and therefore development might not be appropriate on many MOD locations that might be declared redundant. Without the insertion of caveats relating to the conservation and protection of natural beauty the AONB is very concerned that 'green jobs', along with some of the outcomes within paragraph 3.5 relating to climate change, could lead to inappropriate developments and activities that generate additional travel. In paragraph 3.6 it seems rather strange that there is specific reference to 'Western Wiltshire Green Belt' and no reference to the AONBs. Whilst the Strategic Objective is laudable we strongly recommend that this is presented in the context of the national significance of the AONBs. As I have already indicated, the AONBs are particularly concerned about the loss of community facilities within the villages of our AONB and we would, therefore, wish to see achievable ways of retaining these facilities. Moving to paragraph 3.8 it is regrettable that there is no mention of natural beauty and the AONBs whatsoever. There also seems to be a limitation of Green Infrastructure to sites that are publicly accessible and with wildlife value, whereas the original concept promoted by government included a much more holistic, landscape based, concept. Such a concept would, of course, be of considerable relevance to a rural county such as Wiltshire, and the AONB recommends that a more holistic concept of Green Infrastructure is adopted. I question whether, in key outcomes, agricultural soil quality can be improved through planning policies and planning actions. It also appears as though another key word has been omitted in connection with water abstraction and that the key outcome should read 'the adverse environmental effects of water abstraction will have been reduced'. Regarding high quality design and the historic environment (which, as I have already mentioned, could be separated into two objectives) there seems to be an especially hopeful use of words in the third bullet point. There 'exceptional' could, as seems to have been intended, mean high quality, whereas it could be exceptionally bad! Similarly in paragraph 3.10, first sentence, the reference to 'convenient locations throughout Wiltshire' could be misinterpreted as providing a clear steer that major supermarkets would be welcomed everywhere. Strategic Objective 8, paragraph 3.11, seem to have inbuilt conflicts in relation to improving the opportunities to use public transport when the major thrust of the Core Strategy seems to be seeking to discourage commuting. Nevertheless, from the point of view of this AONB, we would like to see the opportunity to use public transport being enhanced and that the railways that already cross the AONB should be more readily accessible to residents and visitors alike. We are acutely aware that one of the railways, the Salisbury to Warminster line, does not stop within the AONB and consequently brings no benefit to the AONB. Cross Comment No. Comments Officer Comments Issue Reference By 1.1. Strategic Objective 6 : to safeguard and promote a high quality built and historic environment. We support this Strategic Objective - but see below. 1.2. Paragraph 3.9 (pages 20-21): bullet points under ‘Key outcomes' We objec t to the wording of some of the bullet points and suggest the following changes (new or altered wording in red; reasons given (in square brackets) where needed): Where appropriate , Wiltshire's distinctive built heritage will have been used asreference points for new developments. [ Reason : It would not necessarily be right for all new development to reflect the distinctive built heritage of Wiltshire.] New development will have incorporated be of exceptional design quality which fosters community cohesion and where appropriate reflects local character, and which promotes Wiltshire as a desirable place in which to live. [ Reason : This reads better; change also suggested for similar reason as suggested change to bullet point, above.] · The Outstanding Universal Value of the Thank you. Comment noted and the number of Stonehenge and Avebury World Heritage Site will have been protected from inappropriate Strategic objectives will be rationalised in the next 1154 Chapter 3. Q22 development. · The Stonehenge and Avebury World Heritage Site will have been protected version and the wording of all the outcomes from inappropriate development in order to maintain its Outstanding Universal Value. [ Reason : sought will be reviewed. Practically speaking and for clarity in planning matters, Outstanding Universal Value (OUV) cannot be ‘protected' as it is a concept, not an object. It is the WHS itself that must be protected in order to ‘protect', preserve or maintain its OUV: for confirmation, see for example, UNESCO Operational Guidelines 96-99 and 109. We admit that Circular 07/09 gives conflicting advice, saying in one place that OUV must be protected and in another that it is the WHS that must be protected; but its opening ‘Objective' in para.6 makes it quite clear that the UK Government is committed to permanent protection of the World's cultural and natural heritage of OUV through ‘identification, protection, conservation, presentation and transmission of its World Heritage Sites to future generations in accordance with Article 4 of the World Heritage Convention.' [Our emphases] Comment noted. Tourism is an important We think that there should be a section on sustainable tourism in the Core Strategy and 1162 economic sector for Wiltshire and will be SO1 suggest that this is considered, as well as inclusion of a Core Policy on sustainable tourism. considered in more detail within the next draft.

2. 1. Chapter 5.2: Salisbury Community Area Strategy (page 51) 2.1.1. We strongly object to the wording of the South Wilts Core Strategy Submission Draft paragraph 8.25(a) and its Core Policy 13 in relation to the Stonehenge part of the WHS which treats the Stonehenge WHS as though it comprised only the henge monument and not the surrounding landscape as well. This The SWCS is at a more advanced stage of section of the S Wilts Core Strategy was objected to by CPRE at the EIP, with new wording production. The council is awaiting a binding proposed by CPRE and agreed by English Heritage. We prefer to see a revised section on the report from the planning inspectorate. This policy South South 1165 WHS to cover it as a whole, including appropriate policies for the protection of both halves of was discussed in detail at the examination into Wiltshire Wiltshire the WHS, its archaeological landscape (including sites and monuments) and its setting. We the SWCS and proposals put forward suggest would object (as we do to S.Wilts Draft Core Policy 13) to the inclusion of specific development amendments to this policy. proposals for the WHS in the Core Strategy. 2.1.2. We note with concern that the Wilts Core Strategy Consultation Document and S.Wilts Core Strategy Submission Draft are currently not compatible in format or content in relation to the sections on the WHS; nor indeed are they compatible in many other respects. Cross Comment No. Comments Officer Comments Issue Reference By Dear Sirs 1. I regret that I am computer illiterate - hence this typed response. 2. I would like to strongly support Core Policy 1 (CPI) - Para 4.13 respecting the 'Local service centre' of Sutton Veny now classified as a large village withill the Warminster Community Area. 3. You stress your support for the ~Warminster Town Plan'. (Open for consultation again until 2/8/2011). 4. I would suggest that due to present economic circumstances - a major revision is necessary. i) New shopping facilities in Car Park Area - A high proportion of Town centre shops are already empty. ii) The car parking area is underused - Markedly less used since fees were introduced and all free parking now congested. iii) Re-location of the Library - Due I gather largely because of the cost of electricity to provide adequate lighting. Provision of Solar PV on the ideal southern aspect roof could resolve that at a fraction of the cost. The current location is well Support for Core Policy 1 is noted. Comments placed for users. Although you have CP33. The Core Strategy seems to disregard the finite regarding Warminster and Transport have been resource of Grade I and 2 Agricultural Land. This appears unsound when the June 2011 passed on to the relevant officers. Although 1200 'Natural Environment White Paper' (The Natural Choice) continues to protect 'our best and most Warminster where possible Grade 1 & 2 agricultural land Question 1 versatile agricultural land'. , . ' Most of Warminster' s expansion is planned currently on Grade should be kept, this is not always possible and 2. There are alternatives of lower grade. Equally I believe it wrong to build in flood plains Warminster is an example of where other factors (CP49). ii)CP50 (Para 6.10.3) Water abstraction- I believe the housing expectation proposed in have made the choice of this land unavoidable. Warminster in the Plan period.cannot but aggravate an already serious, situation of over extraction in the River Wylye catchment. The main river channel at Smallbrook Millls already Don existent. 5. I hope 3 and 4 above helps answer your Question 18. 6. In general. The Greenfield expansions of Trowbridge (very unpopular with the surrounding villages)and at Melksham together with CP42/CP47/CP48 -;- with Paras 6.820 and 6.821 all support your long held aspiration for the A350 Corridor. , Perhaps it is pertinent to remember that the Secretary of State concluded after the 'Westbury Bypass Inquiry' that the emerging RSS signals substantially less support for the importance of the A350 than may be seen in the extant development Plan. Also that the Dorset LTP3 makes no mention.

Topic Paper 5; legislative Sir, I am afraid I am too busy and far too old to go rushing around looking for the dreaded forms context – one is expected to fill in to get some interest from someone. No doubt it is a brilliant idea The Water Water hatched up to avoid getting complaints ln our garden goes down to the Kennet in Axford. We Framework The comments are noted. Additional emphasis resources; have a very small pond in which the water level follows that of the Kennet. It is unfortunate or Directive; on the existing issues associated with water abstraction disgraceful, depending to what extent you are involved, that the pond is almost dry at the 1207 Catchment abstraction in the River Kennet will be added to issues SO10 moment, at it's lowest level for over 40 years, and the life of about 100 frog spawn and tadpoles Flood Topic Paper 5 to increase overall awareness of (focused on can be written off, murdered quite unnecessarily by gormless water extraction 'policy' pursued Management the water resource matters. the River at the moment by WCC. One is tempted to think the life of frogs is far more important than the Plan; River Kennet). water wasted by the residents of Swindon. That is what should concern WCC, not getting more Basin water from the already shrunken Kennet. Management Plan. Cross Comment No. Comments Officer Comments Issue Reference By Introduction : This note summarises the views of Amesbury Town Council (ATC) on the new Wiltshire Core Strategy (WCS). Previously ATC has commented on the South Wiltshire Core Strategy (CS) and attended the Examination in Public. The ATC comments have been revised in the light of the Coalition Government's decisions on Regional Spatial Strategy (RSS), the Stonehenge Visitor Centre (SVC) with its associated enquiries and the WCS. The fundamental requirement remains constant: that Amesbury will become a larger and better balanced sustainable community, becoming more self-contained as stated in WCS 3.1 and Strategic objective 4. ATC is concerned that WCS coverage of the strategy for Amesbury at 5.4 is miniscule compared with other Market Towns. Bradford has the next five pages whilst Amesbury receives barely five lines referring anyone interested in the Amesbury Community Area Strategy to the earlier CS. The fundamental problem with the earlier CS was its focus on Salisbury. The Amesbury Community Strategic Plan (ACSP) covered issues of housing, retail, education, leisure and employment needs. Salisbury District Council accepted and endorsed the ACSP in 2007. The ACSP was created after, and independently of, the previous Salisbury District Local Plan and partly in parallel with the Salisbury Vision. WCS does not refer to ACSP although it does draw on earlier documents. ATC recommends that WCS should adopt the ACSP as the most current community plan for the Amesbury Community Area (ACA) available to WCS as described in 1.11 to 1.14. This would be in accordance WCS 4.15. The ACSP was a Core Document for the 2010 examination of CS, as it was for the Retail Examination of the ASDA/Tesco applications in 2009. CS paragraph 8.2 identified retail choice as a key issue and this remains true for WCS. The Amesbury Community Partnership (ACP) monitors the progress of the ACSP in co-operation with Amesbury Town Council (ATC) and with the Stonehenge Community Area Partnership (SCAP). CS Section 8 covered the Amesbury Community Area (ACA). Whilst it acknowledged the problems for ACA the evidence base used for WCS appears to be incomplete. The evidence produced so far does not cover the impact from the combination of changes envisaged across the whole area. Transport: The status of the The SWCS is at a more advanced stage of transport network through the Amesbury Community Area in Wiltshire is at a critical break point South South 1295 production. The council is awaiting a binding and must be included in any further plans or proposals for further distribution of housing, retail, Wiltshire Wiltshire report from the planning inspectorate. education, leisure and employment needs. ATC is aware of the problems caused to neighbouring communities, such as Durrington and Netheravon by traffic seeking alternative routes to the overloaded A303. The scope of the improvement of the A303 has been scaled back and delayed although it was seen as an essential enabler to South Wiltshire. CS Paragraph 8.24 recognised the inadequacy of the A303 west of Amesbury and the need to work with the Highways Agency (HA) and Department for Transport (DfT). This should be included in WCS Core Policy 48 as a singular item, if WCS Core Policy 43 is to be achieved. English Heritage has noted in its representations the close relationship between Amesbury and the World Heritage Site. WCS does not appear to have complied with this. Simulation should explore the possible ways that this synergy could be developed, for example through modelling the changes to the flows of visitors to Stonehenge to and from supporting facilities. In 2010 the problem of movement corridors for large Goods Vehicles led to an impasse between local communities without an overall view at the Wiltshire level. This draws into question the soundness of the assumptions underpinning the CS and WCS. As residents of Salisbury have noted in their representations Solstice Park is a major component of South Wiltshire employment. The absence of coverage of the issues arising from the A303 in the WCS is disappointing. This follows concern that Transport documents were added to the CS evidence well after the completion of the other parts of the CS. WCS Draft topic paper 11 mentions the A303 once, in its consideration of the A350 corridor and not at all in its own right. ATC is concerned that these earlier proposals and investments are centred on Salisbury, reflecting the focus of previous documents rather than the broader scope of balanced development across Wiltshire. WCS seems to have continued with this, emphasising housing at Amesbury in Table 5 of Topic Paper 2, but not the supporting infrastructures necessary for that housing to form a sustainable community. WCS 6.7.2 directly refers to using the earlier district plans for Amesbury, although the level of housing now envisaged for Amesbury is now far larger. February 2010 at the Amesbury Area Board saw discussions of the possible de-priming or de- Cross Comment No. Comments Officer Comments Issue Reference By trunking of the A338,. This emphasises the need for decision-makers to take a higher level view of the transport system as an enabling capability for retail, leisure, education, and entertainment. Amesbury town council is concerned that the status of the A303 has not been acknowledged in the WCS. For the region as a whole informed decisions with reliable evidence and simulation modelling would indicate likely levels of benefit to the communities in Wiltshire, such as anticipated levels of sales, access to leisure facilities numbers of pupils educated per year and capacity of types of leisure offerings as well as the detriments based on numbers of vehicle movements,. These assessments will act as evidence to inform appraisal and evaluation of possible options for development. The WCS requires a similar level of detail in its evidence base for Amesbury to that applied to Salisbury in the CS. The CS acknowledged the discrepancies in the coverage of Amesbury. 8.18 recognised that Amesbury has not been acknowledged as regards employment. 8.20 acknowledged changes from the previous local plan as regards Solstice Park. The extensive changes to anticipated developments in employment, retail, the Stonehenge Visitor Centre and the much larger amount of housing now in prospect in the WCS will cause impacts which have not been considered as a whole. These impacts are the outputs of systems which can be measured in quantitative and qualitative terms. The WCS does not seem to have considered impacts from these systems which may be positive, such as visitors to Stonehenge, with associated benefits to local retail sales or negative such as numbers of homes affected by high levels of large goods vehicle passage affecting their amenity. (Amount of Open Space Audit referred to as main area without provision 17.7 hectares App 7 included all sites in army camps with some degree pf public access and predominantly located in relatively low population density areas S/2009/0843 Land to rear of Lyndhurst Space Cllr J Noeken) Housing : The scope of the Kings Gate development is now substantially greater than that originally envisaged and approved by Salisbury District Council for the area to the West of Boscombe Down airfield. Education Capacity has already been identified as out of step with the likely additional population for Amesbury. Whilst there are plans to extend Archer school and build another school whether these will offer enough school places by time for the anticipated population has not been assessed. Lack of analysis of the likely impacts on the amenity of Amesbury is a gap in the soundness of the evidence base for the WCS. There appears to be a lack of evidence on the level of the housing needs. ATC also feels that the percentage of Low Cost housing suggested within the proposed housing increases needs reconsidering. For the WCS to be valid as the foundation for the assessment of options for the future of Wiltshire consideration of the place and role of both Amesbury and Salisbury in South Wiltshire is essential. Amesbury Town Council welcomes the opportunities from the consultation to consider Amesbury's role within Wiltshire and so ensure that the WCS reflects this on a sound basis for future development. There are three canals in Wiltshire none of which appear to be included for protection in theWiltshire Core Strategy Consultation Document. The three are: 1) The Kennet and Avon Canal - restored and fully open to navigation in the south of the county 2) The Wilts & Berks Canal - under active restoration in several parts of central Wiltshire and in neighbouring Oxfordshire 3) The Cotswolds Canals - also under major restoration though only a very small part is in north Wiltshire. These three canals will form a network in Wiltshire; the Kennet and Avon being joined eventually with the Cotswolds Canals by the Wilts & Berks Canal and This issue will be considered for the pre- Swindon will also be linked to the Thames at Abingdon by the Wilts & Berks. A very submission draft core strategy. Consideration will considerable amount of work has been carried out on these waterways largely by labour and 1299 be given to including specific policy protection for Canals SO5 professional input by volunteers. I am concerned that, while the Wilts & Berks Canal the proposed Melksham link route and the historic Partnership includes both Wiltshire and Oxfordshire counties, the historic and proposed new canal alignments. alignments of the canal are not protected in the Core Strategy. Two major sections, the Wichelstowe route south of Swindon and the new link from Semmington to Melksham are in advanced stages of construction or detailed planning. Of necessity canal restoration initially takes place in isolated sections and over a long timescale due mainly to funding. This therefore must be supported by a clear statement that the historic and new lines of the canal are protected. There is very considerable evidence from the canal restoration projects that have been carried out nationwide in the last 30 years that the social, healthy living, wildlife and Cross Comment No. Comments Officer Comments Issue Reference By leisure benefits from canals are considerable. Indeed they are instrumental in delivering biodiversity and leisure outputs for relatively little cost to the public purse. There are many canal networks in the midlands and north of the country but relatively little at present in the south. Wiltshire's canals will form part of three circular routes to redress this deficiency. I would therefore urge that the protection that was afforded by the formerWest Wilts District Council and North Wilts District Council be included in the proposed Strategy.

Country Land & Business Association Most of the 35,000 members of the Country Land & Business Association (CLA) are by definition rural landowners. CLA members' businesses manage land, generate jobs, provide land and buildings for investment and housing for local people, and participate in environmental land management programmes. Land is therefore the principal asset of CLA members and its value depends upon the use to which is it put under Planning policy. Our member's core businesses included agriculture and forestry. However, rapidly declining real incomes in these traditional rural industries has led many of our members to look to alternative but compatible business ventures. Many of these businesses now include tourism, food production and processing, educational facilities, sport and recreational facilities and many other types of diversification. In addition, the re-use of existing buildings has enabled many land managers to provide offices and light industrial units to local entrepreneurs whilst Noted, this will looked into and the possibility of 1306 generating rental income to support the rural business. This diversification is in line with inclusion of a policy that supports rural life SO1 government guidance provided in PPS7. These businesses have moved from their traditional considered. roots and are very much rural enterprises. Our members are particularly interested in the issues affecting rural areas being land managers who are ultimately responsible for the stewardship and management of those areas. It is these rural businesses which provide the countryside management that maintains the rural environment in a form which we all recognize and treasure. Accordingly, the CLA's primary benefit to its members is to influence rural planning policy in the public interest and for the benefit of its members. We recognize the importance of the planning system and therefore have a keen interest in the preparation of this plan. The issues that we believe are of particular importance to the sustainability of the rural economy, rural communities and environment of this district are as follows: ( see other comments on this document by the County Landowners Association ) Cross Comment No. Comments Officer Comments Issue Reference By Relationship with Neighbourhood plans Sustainable development and planning The Government is committed to ensuring that the planning system does everything it can to support long term, sustainable economic growth, and has made it clear that significant weight should be placed on the need to support economic recovery through the planning system and related consent regimes. The core strategy should reflect the government's new approach to sustainable development which involves making the necessary decisions now to realise their vision of stimulating economic growth and tackling the deficit, maximising wellbeing and protecting our environment, without negatively impacting on the ability of future generations to do the same. The three 'pillars' of the economy, society and environment are interconnected. Our long term economic growth relies on protecting and enhancing the environmental resources that underpin it, and paying due regard to social needs. To help achieve this, the Government's clear expectation is that we move to a system where the default answer to development is 'yes', except where this would compromise the key sustainable development principles set out in national planning policy. Planning should help to deliver: a strong, flexible and sustainable economy, by ensuring that sufficient land of the right type, and in the right Noted. The Core Strategy is an economic growth places, is available to allow growth and innovation; and by identifying and coordinating 1308 led plan it will be looked at to see how this can be Chapter 1. Q22 development requirements, including the provision of infrastructure protection and strengthened so this is cleared. enhancement of our natural, built and historic environment, prudent use of natural resources and actions to mitigate and adapt to climate change, including moving to a low carbon economy strong, vibrant and healthy communities, by providing an increased supply of housing to meet the needs of present and future generations; and by creating a good quality built environment, with accessible local services, that reflects community needs and supports well-being A presumption in favour of sustainable development The presumption is key to delivering these ambitions, by creating a positive, pro-development framework, but one underpinned by the wider economic, environmental and social provisions in the National Planning Policy Framework. The presumption is as follows: There is a presumption in favour of sustainable development at the heart of the planning system, which should be central to the approach taken to both plan-making and decision-taking. Wiltshire's Local planning authority should plan positively for new development, and approve all individual proposals wherever possible. All of these policies should apply unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits, when assessed against the policy objectives in the National Planning Policy Framework taken as a whole. Cross Comment No. Comments Officer Comments Issue Reference By Paragraph 2.11: Employment Rural Employment In the interests of sustainable development, policies must recognize the need for local jobs backed up by sound up-to-date Employment surveys; matched by housing, services and facilities. These matters are essential as a means of tackling social exclusion that already exists in some rural areas within the district. The Core Strategy must positively encourage viable and vibrant rural businesses capable of offering attractive career opportunities to the younger generation. This will include the need for positive policies to assist the diversification of the core agricultural and forestry businesses, including those farming businesses located in designated areas. Paragraph 2.12: Housing Housing needs in rural areas The CLA calls for the core strategy to permit villages and smaller A Monitoring Framework will be developed settlements to grow incrementally (in line with articulated neighbourhood plans) with policies alongside the Core Strategy, which will set out the that loosen village envelopes and the use of the rural exceptions site policy (PPS3). Core way in which employment and housing provision Strategy housing policies must encourage new small-scale well designed rural housing are monitored. This will be key in ensuring that development of all types (affordable/shared equity and open market) in all rural communities the objectives of the plan are achieved. Core whether or not the settlements are able provide shops, schools or public transport. It is Policy 25 sets out a mechanism to ensure that unsustainable to direct new housing development to only a few local service centres because of rural employment is supported.The Core Strategy the pressure that this puts on local services. The Core Strategy must consider the possibility of identifies those settlements at which development the use of cross-subsidy from limited open market housing to affordable housing on exception would be sustainable. These will be reviewed in 1309 Chapter 2. Q22 sites, in order to increase the levels of private financial support and increase the amount of the development of the pre-submission draft of affordable rural housing. The Core strategy must consider the impact fact that rural the Core Strategy. If development beyond these businesses will not succeed if employees with the appropriate qualifications or experience are settlements is required, the plan provides the deterred from joining or staying at these businesses because of a lack of suitable housing. flexibility to deliver these as either exception sites Paragraph 2.19: Environmental Quality / Landscapes (Core Policy 34) Designated areas [1] or through the development of a neighbourhood Recognition that the designation of an area of land alone will not ensure its protection and plan.Core Policy 33 sets out how environmentally enhancement. This can only be achieved by appropriate positive management and this is best sensitive sites will be protected. The participation delivered by viable rural businesses. When designating land and developing policies the LDF of local businesses in this process will be policies must consider the needs of those rural businesses and how those policies will impact supported as appropriate on a site by site basis. on these businesses. They should also consider what additional resources could be made available to assist those businesses in the positive management of the countryside. Furthermore, recognition must be given to the changing nature of agricultural crops/enterprises and thus the need to grow renewable energy crops to assist in the Government's targets e.g. miscanthus and biomass. In order to meet the needs of agricultural policies farmers in designated areas must not be prevented from growing such crops through misuse of the Landscape Character Assessment tool/process. [1] Designated areas: National Park, Areas of Outstanding Natural Beauty, Green Belt

Strategic objective 8: to promote sustainable forms of transport Core strategy policies should not restrict the mix of development in the countryside. Nor should it limit the location of development to public transport routes, because so much of the countryside and its economic Agree. The Core Strategy will allow a flexible and success will always be dependent on the car and road based freight transport. (as outlined in pragmatic approach to development and it will PPS4 below) Development control should fully reflect this positive approach. The core strategy allow for development within the rural areas should positively encourage a greater mix of economic development in the countryside, 1310 where there are important economic or social Chapter 3. Q22 including rural tourism/leisure, renewable energy and other new uses of land and buildings. reasons for doing so. Specific polices on PPS4 PLANNING FOR SUSTAINABLE ECONOMIC DEVELOPMENT, Paragraph 32 In rural supporting rural areas are being developed to areas, recognising that accessibility - whether by private transport, public transport, walking and allow just this. cycling - is a key consideration, local planning authorities should recognise that a site may be an acceptable location for development even though it may not be readily accessible by public transport; Cross Comment No. Comments Officer Comments Issue Reference By Paragraphs 1.10, 2.12, Paragraph 1.10 talks of boosting the economy to reduce out- commuting. Paragraph 2.12 notes that Wiltshire's residential income is relatively high but work place earnings are low. This is further discussed at TP17 paragraph 3.5 where it is said that in 2008 10% of the working population were out-commuters and that the average pay of those resident in Wiltshire was £2,500 greater than the average of those who worked in Wiltshire. The reference is the Annual Survey of Hours and Earnings, ONS. I have looked at the ONS website and found similar figures for 2008 and 2010 but none exactly the same, I emailed the Spatial Planning Team with a query, but have not yet received a reply. However the implication is that if the 10% of out-commuters figures are added to those of the 90% of those who work within Wiltshire and the increase in the mean of the whole is £2,500 per annum, then the out-commuters earn £25,000 a year more than those working in Wiltshire on average. The mean figure for those working in Wiltshire in 2010 was £22,752 so the out-commuters will on average earn of the order of £48,000. A number of deductions can be drawn. With that pay difference it is not going to be possible to stop out-commuting or, with circumstances anything like they are at present, significantly reduce it. I question whether the council should even try. The out-commuters will spend a significant amount within Wiltshire and pay council tax in Wiltshire and other authorities are providing the infrastructure. Out-commuters are a good thing in general, although maybe not the best. (I am not one myself) If Wiltshire is to enter the job Noted. The aim is to create the correct business 1320 market at the out-commuter level it has to present high quality infrastructure to potential environment to encourage higher-value Chapter 1. Q22 employers. Paragraph 6.1.9 comments on the requirements of business thus: "The needs of companies to locate in Wiltshire. new businesses in the future are likely to become increasingly more focused on the quality of sites, premises and people. As businesses move away from the traditional ties of access to raw materials and local markets, the ability to attract and retain the right quality of staff (especially skilled workers) and the creation of an appropriate working environment are primary investment decision factors. Consideration of site environment, good infrastructure, including high speed broadband and proximity to a centre of population, will become increasingly important factors for growth businesses." Much of this is true but it underestimates the increasing requirements of business for fast rail and road access to and by a wide range of customers. Intergraph UK, a global provider of engineering and geospatial software, is based in a Swindon business park with swift access to a major station and the M4. Its marketing people need to get to all parts of the country quickly and their customers need to get to Swindon to run tests and see demonstrations. A company such as this demands excellent road and rail services. That is what businesses "moving away from the traditional ties of access to ...... local markets" means. Broadband is a red herring. Compared to road and rail it is quickly and cheaply upgraded and communications companies will be quick to provide to any significant demand centre. Paragraph 3.6 of Topic Paper 17 notes the 5000 out-commuters going to Swindon and Bath. Going to Swindon is only out-commuting by bureaucratic fiat. It is not a foreign country. As we all do not have computers to reply-this was delivered to me at 11.37AM on SAT 6 AUG Consultation 1321 for postal reply on MON 8 AUG- Post collection here has already left until Mon AM! Anyway Comments noted. Q22 process why bother asking wilts council take no notice of anything.

I note that Maps 5.1, 5.2 and 5.19 do not show the M4, surely a ruling feature in these Community Areas. The M4 corridor is the obvious place for development in Wiltshire and the The maps will be redesigned to include transport 1329 council should move a proportion of their proposed development plans to settlements other routes. Extensive discussions have taken place Maps Q22 than Chippenham in the corridor. Have discussions with the MOD on the closure of Lyneham with regards to Lyneham. not provided opportunities?

Core Strategy Policy 1- Settlement strategy this is supported. It is refreshing to note that representations made to the previous core strategy draft have recognised the support for 1352 Support Noted Question 1 realistic levels of development in rural Wiltshire villages and have included a policy to enable this. Cross Comment No. Comments Officer Comments Issue Reference By

The North Bradley Parish Council considers that the Wiltshire Council is using 'Steam roller' tackics to implement the core strategy and is not paying sufficient attention to the effects upon the people they were elected to represent. The proposals should be scaled down to the use of Comments noted. The strategy includes a 1419 brownfield sites and realignment and use of existing disused premises and the proposed use of previously developed land target of 35%. Question 2 Greenfield sites abandoned. For the reasons outlined above, the North Bradley Parish Council Objections noted. objects to the implementation of the Wiltshire Core Strategy and to the Trowbridge Community area Strategy in particular.

This is supported. It is refreshing to note that notice has been taken of representations taken 1433 last year which requested larger villages should be enabled to accept growth to maintain and Support Noted. Question 1 encourage their social cohesion.

Comments noted.Transport strategies will be Chapter 2 - What is Wiltshire like now? We agree that employment needs to be centred in the developed in Chippenham, Trowbridge and settlements to reduce out-commuting which generates large traffic volumes through settlements Salisbury and may also be developed for other like Holt at the morning and evening rush hours. Traffic volumes on the B3107 through Holt urban and rural areas in the plan area. Proposals have a major impact on the quality of life in the village. The Strategy needs to address in more for delivering the strategic sites proposed in the 1435 SO8 Transport SO8 detail the impact of economic growth and new housing on traffic volumes and the provision of Core Strategy will need to include a transport adequate road infrastructure. Vague statements about improved public transport, pedestrian assessment and strategy to ensure adequate routes and cycle paths are unlikely to resolve the traffic problems of today let alone the impact road infrastructure is provided and that of economic, population and housing growth. sustainable transport measures support the delivery of the sites.

Chapter 3 - Where does Wiltshire want to be? We support Strategic Objective 1 which focuses on development that will encourage economic vitality. We would like to see a strategic objective Support welcomed. A suite of polices within that addresses traffic issues which are not addressed by Objective 8 in promoting sustainable 1436 Chapter 6 of the Core Strategy will set out Chapter 3. Q22 forms of transport. The road infrastructure in the County needs to be developed to reduce the measures to manage traffic and congestion. existing blight of heavy traffic on certain settlements and to specifically address the real growth in traffic that will occur during the plan period.

I write on behalf of the Chalke Valley Preservation Society in response to the emerging Wiltshire Core Strategy Development Plan Document. It is appreciated that this document covers the rest of Wiltshire and does not cover the Salisbury Area. The Society is responding to Noted. The document is promoting sustainable the Inspector as regards that document and the further representations on this are due by the development particularly through core policy 2 29th.August 2011. A concern does arise in that the Wiltshire Core Strategy does not contain and the allocations in the Community Area 1455 any reference to a "presumption in favour of sustainable development". It is appreciated that Question 1 policies. However, it will important for the this document has only been published in draft this July but clearly the policy framework will document to reflect the changes in national policy have to be included eventually. The main concern of the Chalke Valley Preservation Society is and the draft NPPF the policies and assessments for development in the villages and the rural area. The Society does not accept that the system in the emerging Wiltshire Core Strategy is suitable for South Wiltshire Cross Comment No. Comments Officer Comments Issue Reference By

Many of the community areas associated with this AONB are within South Wiltshire. Nevertheless there is still some confusion in the AONB, and the AONB Team does get asked questions about this topic, regarding the allocated numbers of houses and the extent to which The overarching policies of the two document will the communities of the AONB might be expected to accommodate some elements of this be merged to form a number of single policies. housing. The AONB suggests this needs further clarification. Although the Salisbury Community Specific housing numbers are only being planned Area is outside of the AONB it is sufficiently close to be of significant influence, particularly in Relationship 1456 for market towns and communities beyond this Q22 terms of jobs, shopping, and mains services. Mere, Southern Wiltshire, Tisbury, and Wilton with SWCS have and overall target for each community area. community areas are within or include significant parts of the AONB and are in the South Wilts It is expected that more complete housing Strategy Document. Warminster is the single community area that includes the AONB and is allocations will appear in subsequent DPDs. within the current document. Nevertheless the AONB is concerned that the wording of the over- arching policies will relate to all of the community areas and hence the relationship of those polices to the over-arching policies within the South Wiltshire Document.

This section relating to the delivery of the strategic objectives seems to fall more logically before the discussion of the individual areas and the allocation of housing and employment requirements. The AONB WOUld, therefore, recommend that the Core Policies section is moved forward, before the Community Area policies in the final document. The AONB is Consultation 1457 Comments noted. Q22 grateful for the opportunity to contribute to this significant policy document and I hope these document comments are helpful to you. I WOUld, of course, be happy to discuss any of the points with you and to contribute to the consideration of other comments and revisions. If it would be helpful to you AONB team members could be available to meet with you.

More emphasis should be placed upon the necessity for sequential development. It should be pointed out that although the phrasing sounds nice we should have moved on and recognised that to date the large developments in Swindon have not led to successful sustainable Noted. Although we try and place housing communities, but to a rise in crime and a dead centre. Now it seems that there is a swing to development in our town centres where possible 1470 Chapter 1. Q22 recognition that a lively town centre is the basis for economic growth. Does the five-year land many of our centres lack such sites whilst need supply compromise such a move? Regeneration should come first, followed by other areas more housing etc. after the centre has been regenerated. It is good to see that the sequential approach is used in Policy 41 for retail and leisure and in 6.7.5 for flooding. Cross Comment No. Comments Officer Comments Issue Reference By Noted - National policy, particularly in the form of PPS3 & PPS4, states that through the Core Strategy the council should promote greater levels of development at settlements with the We suggest Housing and employment figures need to be lower. 175-182 hectares of new facilities and infrastructure to support that employment land appears high. Account should be taken of the rise in internet shopping, development and provide the best opportunity to working from home and the closing down of shops. Allowance must be made for the effect of offer jobs and homes in the most sustainable climate change on water supplies in the South of England by 2026. When will 27,570 jobs be manner. The designation of the principal delivered? 37,000 homes is a relatively large figure when compared with nearby areas - settlements allows the best opportunity for account must be taken of the strain on resources and infrastructure. Strategic sites - Master 1471 Wiltshire to fulfil its requirement for jobs and Question 2 Plans appear not to have achieved successful development in Swindon. Young people tend to homes within environmental limits. Topic paper move in, and when years later they move on, there seems to be a closing down of schools etc. 17 paper sets out the progress made in Delivering infrastructure: In this area we would object strongly to green infrastructure being determining an appropriate requirement and taken if it can be provided elsewhere. Where major towns are expanding there are now highly distribution of housing for Wiltshire from 2006 to valued landscapes and these must be retained as well as the protection of the separate 2026 to inform the draft Wiltshire Core Strategy. identities of existing communities. This process considers the strategic objectives for the county as well as taking into account local factors and aspirations for growth identified through community consultation. We suggest transport issues have to be looked at in closer detail, reference Policy 47 re the Comment noted. Further work on freight is 1474 SO8 Freight SO8 movement of goods. carried out through the freight strategy.

We strongly support the new sensitive proposals for Gypsy sites. Nevertheless, we feel North Wiltshire has already borne the brunt of previous allocations, and future allocations should be directed to other areas. Locally there is rising concern among many residents when they see 1475 Comments noted. SO3 sites being set up in delightful areas - and away from facilities. They point out that they are unable to enjoy such a privilege. Locally it is felt that there should be a guide percentage of such sites vs. the local numbers of residents as we can foresee problems arising in the future.

6.5.18 It is not clear whether the Swindon & Wiltshire Structure Plan and DP13 (relating to the RBZs) are to be retained with the new WCS. This needs to be made clearer. Nowhere is the term ‘Countryside' mentioned. This needs to have greater protection, to maintain our rural areas. What influence will the Wiltshire Green Infrastructure Partnership have? Although the An explanation of the position in relation to the first paragraph states that the policies were not saved because they were considered to conflict Wiltshire and Swindon Structure Plan will be with national planning policy, the Government has now said they would protect highly valued added for the pre-submission draft core strategy. landscapes. E.g., after Greg Clarke's statement in the House (which was used in evidence at It is envisaged that the Structure Plan will be the Hook Street 175 house development appeal) the value of landscape and areas of special revoked by central government, and in the event importance was upheld. We support the need to protect the landscape, as well as the 1477 that it is not then all the Structure Plan policies Rural buffers SO5 uniqueness of individual settlements, both of which the Core Strategy recognises to be prized will be superseded by the Core Strategy. objectives by the local community. It is important for this strategy to be taken forward by Consideration will be given to adding reference to appropriate and strong policy mechanisms. Housing growth in the main settlements to improve the need to protect the countryside in the Wootton their vitality and create a critical mass to deliver improvements in infrastructure is necessary. Bassett area strategy in the pre-submission draft However, given that there are a number of existing outstanding housing commitments, future core strategy. housing growth in Wootton Bassett and elsewhere must always be phased to enable infrastructure delivery alongside housing growth. We support the proposal for Wootton Bassett to be the main location of strategic employment growth to help reduce out commuting in the Northern area. Cross Comment No. Comments Officer Comments Issue Reference By An appropriate approach to the Wiltshire GI Standards will be considered for the pre- submission draft core strategy. It may be that it Green 1478 We request that the Wiltshire GI standards in Policy 36 are added to the Core Strategy. would be more appropriate for the Wiltshire-wide infrastructure SO5 standards to be developed and adopted through standards a separate process, such as a later planning policy document. Comments noted. The strategy includes a specific Strategy should include a specific interpretation of "the design of buildings should be site 1479 policy which seeks to promote a high quality built SO6 specific". environment. In terms of Junction 16 of the M4, this is managed by the Highways Agency - Wiltshire Council have met with the Highways Agency and Swindon Borough Council to discuss improvements to this junction. In terms of safety on the A3102, the The proposed improvements to M4 Junction 16 are thought not to be safe - the lane markings proposed core policy 43 (transport and 1480 are too narrow for lorries on the bends and the cross-over is not in accordance with DMRB. M4 and A3102 SO8 development) in the June 2011 consultation Safety on the very busy A3102 is most important. document indicates that, where a transport assessment is required, development proposals will need to demonstrate that "the proposal is capable of being served by safe access to the highway network".

6.10.2 If sufficient homes cannot be housed on normal land or Flood Zones 1, consideration Flood risk should be given to refuse such applications. This is creating unnecessary dangers, and the PPS25, draft Although the comment is noted, national policy management; likelihood of uninsurable dwellings. We support the proposed re-opening of rail stations, NPPF; (PPS25) does not preclude housing development appropriate especially the one at Wootton Bassett. We are pleased to note that the Regional Spatial Strategic within more critical flood zones. Matters in level of control 1481 SO10 Strategy (RSS) has been abandoned by Central Government. The Core Strategy that has Flood Risk relation to regional planning (forecasts, targets, over replaced it promises to give more accountability to locally elected representatives and an Assessment, policy and relationship to lower order plans) are development improved model for local residents to have input into any development proposals. This is good CP51. noted. within critical for local democracy. flood zones.

SO4: To help build resilient communities: This objective cannot be achieved without The Core Strategy seeks to strengthen preventing the break-up of existing strong communities. The community of people living on communities and not break them up. It is not the 1530 boats in Wiltshire is a strong community that is currently under threat from British Waterways Chapter 3. Q22 role of the Core Strategy to intervene in legal unlawful enforcement activities. The Core Strategy should include measures to prevent the disputes. break up of this community.

The opportunity to comment on the Wiltshire Core Strategy is welcomed, however it is noted that detailed assessment of the document will only be possible following the release of the Consultation 1533 evidence base and topic papers which support the strategy. It is recognised that site specific Comments noted. Q22 process allocation and justification is not appropriate at this time but will be addressed during the evolution of the strategy and through the forthcoming consultation process. Cross Comment No. Comments Officer Comments Issue Reference By

Thank you for the opportunity to comment on this document. We very much welcome Wiltshire's progress in developing a Core Strategy as this will help ensure that plans for the future our area are shaped by the community and not driven only by developers profit motives and Inspectors decisions. Friends of Woolley is a community association for the small but distinctive community of Woolley set on the northeastern edge of Bradford on Avon. We are Noted. The contents of the draft Plan for Woolley Plan for 1539 preparing our own Plan for Woolley 2026. We have used the recent well attended consultations will be taken into account in the preparation of the BoA Woolley on our own plan to pull together our response to the Core Strategy Proposals. About 80 people pre-submission draft core strategy. have input their ideas, helping to frame this community response. Our draft plan is in the process of being put together and can be made available should you wish to see it. Further information on our association may be found on our web site at: http://www.friendsofwoolley.org.uk/index.html

The rural context is recognised in the Transport Topic Paper, which states for example that "In a rural area such as Wiltshire, encouraging modal Strategic Objective 8 – promote sustainable forms of transport Fundamental failure to recognise shift or reducing travel demand can be difficult. the rural planning context within the transportation policies et al. Detailed assessment of the However, in the larger settlements, particularly 1543 Rural areas SO8 policy context that seeks delivery of SO 8 can only be made upon sight of the evidence base Chippenham, Salisbury and Trowbridge, there is and relevant topic papers. more scope to do so. Some smaller towns such as Westbury, Bradford on Avon and Warminster also have a higher degree of connectivity" (para 6.9). A. STRATEGIC OBJECTIVES (CHAPTER THREE) § 3.2 The strategic objectives have been revised. These are listed below, together with amendments proposed by Bradford on Avon Town Council ( underlined ): Strategic objective 1: to deliver a thriving economy which provides a range of job opportunities. Strategic objective 2: to address climate change. Strategic objective 3: to provide everyone with access to a decent, affordable home. Strategic objective 4: to help build resilient and sustainable communities. Strategic objective 5: to protect and enhance the natural environment Strategic objective 6: to safeguard and promote a high quality Suggestions noted with thanks. The number of built and historic environment Strategic objective 7: to enhance the vitality and viability of town 1557 Strategic objectives will be rationalised in the next Chapter 3. Q22 centres Strategic objective 8: to promote sustainable forms of transport Strategic objective 9: to version. ensure that infrastructure is in place to support our communities Strategic objective 10: to minimise the risk of flooding and effective water management. § 3.8 Under ‘KEY OUTCOMES’ first bullet, omit “Where possible...”. Bullet now reads: “Development will be directed away from our most sensitive and valuable natural assets, towards less sensitive locations.” § 3.9 Under ‘KEY OUTCOMES’ first bullet, add “... and their settings”. Bullet now reads: “Features and areas of historical and cultural value, and their settings, will have been conserved and, where possible, enhanced.” Cross Comment No. Comments Officer Comments Issue Reference By The quantity of documentation in this consultation is excessive and makes comprehensive comment on the whole of it impossible within the time and resource available. Comments are therefore limited to a few key issues and focussed on the Devizes area. A more carefully considered and more concise document, limited to proposals that are realistic and achievable, would have been be preferable. The approach should be quality rather than quantity. It is an error in a significant failure of the management of the planning system to have allowed such documents to have been produced for public consultation. The overall impression is a mass of documents filled with all the undigested utopian ideals and wishful thinking that could be included . There are inherent conflicts and contradictions within the documents because they contain so much. The key objectives are an unselective list of all that could be considered as possible desirable , rather that what priorities are realistically achievable. There is no indication of how any of the desired outcomes could actually be achieved and no specific actions are proposed to achieve the desired objectives. There is much reliance on jargon words to give the impression of sound policies and proposals, but they often do not bear detailed Comments noted. Every effort is made to ensure consideration. The terms "sustainability" and "resilient communities" are used frequently in an the document is readable and understandable to attempt to confer respectability on some dubious concepts and proposals. The very terms are all. It is also necessary to ensure that the ill-defined and questionable. Sustainable development is defined in the Appendix as document is detailed enough to withstand scrutiny development that meets the needs of the present without comprising the ability of future .The Core Strategy proposals are supported and Consultation 1558 Q22 generations to meet their own needs. That The definition is vague and it would fit almost any justified by evidence set out in the Topic Papers. process situation. Who can tell what the needs of future generations might be? Certainly not the Evidence gathering is ongoing and further work planners, who have conspicuously failed over recent decades to plan for today. There does not will be taking place to ensure they are as up to - appear to be a definition of resilient communities, which is not acceptable when it is a theme date as possible to ensure that the Core Strategy constantly used throughout the document. Presumably it means communities that can cope is a sound document. with whatever is imposed on them. Para 1.10 states: "Underpinning this strategy is the delivery of resilient communities through boosting the economy in order to achieve a greater level of self containment in settlements and provide the jobs locally that Wiltshire's communities need." That implies that resilience basically requires community self-containment. That is doubtful. What may be more important as a test of resilience is that a community remains as an attractive place to live from decade to decade. Although the Devizes Area as a whole remains an attractive place to live, it is relatively less attractive than it was 15 years ago, which implies that its resilience has been undermined by past planning policies. For a rural county, it is surprising that agriculture does not feature in the document. There is much importance placed on localism, the views of local communities and the production of neighbourhood plans. Wiltshire Council has not shown itself to be adept at considering local views. It needs to change its attitude if the stated objectives are to be achieved and our communities are to be truly resilient.

This chapter begins relatively well. Para. 1.3 in particular identifies a the key problem: "The strategy recognises that previous growth hasn't always been delivered in a proportionate manner whereby housing has been delivered in settlements where there are insufficient employment opportunities leading to out-commuting. Perhaps the key message from our Noted. The key outcomes under the strategic communities during the preparation of this document was that whilst there was an objectives aim to provide some clarification of understanding of the need for new homes there was little appetite for more homes, without the how the strategy will be delivered. Infrastructure imbalance in local jobs and the infrastructure required to support growth being addressed. The is an important aspect of the Core Strategy and strategy is therefore to redress this imbalance and support a more sustainable pattern of an Infrastructure Delivery Plan will be prepared development within Wiltshire." It is a pity that the remaining documentation gives no 1559 alongside the final core strategy to ensure that Chapter 1. Q22 confidence that the problem can be satisfactorily addressed. The consultation document is full such facilities are provided. This is now a of desirable aims but short on realistic ideas on how they can be attained. It is evident that the requirement. Without such infrastructure the policies of the past 15 years have made life worse for people in Wiltshire in many respects. council will not be allowed to take sites forward. There is now a significant infrastructure deficit. The great amount of housing built without the The IDP needs to be supported by information infrastructure essentials has reduced the sustainability and the resilience of communities from infrastructure providers themselves. because it has drawn people into the County from elsewhere and arguably compounded the problems. . Tourism and its great economic potential has been neglected, perhaps because there is currently no policy or vision for how it can be developed. Tourism policy has been focussed on a few existing sites in favoured areas instead of seeing it as a county-wide industry Cross Comment No. Comments Officer Comments Issue Reference By with great potential. Paragraph Para. 1.4 states, "1.4 There are a number of key principles which underpin the proposed strategy to help build more resilient communities, as follows:" This paragraph warrants some detailed comment. It is unrealistic and utopian when taken as a whole. Resilience should be defined here if it is such a basic requirement. Is resilience considered to be dependent on sustainability, or has the jargon got in the way of intelligent thought? Commenting on the bullet points: "1.4 There are a number of key principles which underpin the proposed strategy to help build more resilient communities, as follows:" • Providing for the most sustainable pattern of development that minimises the need to travel and maximises the potential to use sustainable transport. There is no indication how this could be achieved. There are many reasons why modern life requires travel for social or recreational reasons and for work. Families tend to be far more geographically widespread today and, as people live longer, that trend will increase. Housing estates are no longer clustered around a single employer and people are forced to change jobs many times in their lives, often necessitating commuting over large distances because moving house has become difficult and costly for many reasons. In larger towns and cities there is a variety of employment opportunity within reach by public transport and higher population density makes it more economic and sustainable. It follows that development should be more focussed on the major centres of population that can sustain public transport. . The population growth in smaller towns in the past 15 years has led to a big increase in commuting to the larger towns because that is where the better jobs can be found. In more rural areas public transport is uneconomic and unsustainable; it is the small family car that has become the sustainable mode of transport for rural areas. Creating the right environment to deliver economic growth, delivering the jobs Wiltshire's population needs locally, and taking a flexible and responsive approach to employment land delivery. The implication here is that the right environment can be delivered. That has not been the case in the past, how why is the future to be different? There is no statement as to what the right environment is or how it can be created. Phasing development to ensure that jobs and the right infrastructure are delivered at the right time to ensure that out- commuting, in particular to areas outside of Wiltshire, is not increased and development does not have a detrimental impact on infrastructure. This is an issue of planning ; and creating the infrastructure prior to building houses. This is and not just housing, contrary to past planning practice and in some areas, such as Devizes, there is a serious infrastructure deficit. Can the policy be changed for the future? Politics and economics may work against that if the current Localism Bill becomes an Act and developers are even less controlled in the future. The reference to out-commuting to areas outside Wiltshire is misconceived; the problem for Devizes is out-commuting to other Wiltshire towns. It is also difficult to see why the desirable objective of ensuring that development does not have a detrimental impact on infrastructure is linked to the statement about out-commuting will probably work against that . Working towards lowering Wiltshire's carbon footprint through providing renewable energy, sustainable construction and location of development. This is probably unrealistic and not a suitable key principle for building resilient communities. Wiltshire utopian nonsense. Who is not well placed to make a significant contribution to the provision of provide renewable energy . and at what cost? It has no large rivers and no upland consistently windy areas that are not protected landscape. Its agricultural land could be used to produce biomass crops but that would not be a good use of fertile land. Sustainable construction and a reduced carbon footprint are not necessarily compatible. This seems to be a thoughtless linking of political jargon and is not acceptable as policy. The main driver for reducing the carbon footprint is energy cost and the . The Government is driving up energy costs in various ways and Wiltshire Council is not likely to be able to make a significant difference. Protecting and planning for the enhancement of the environment, wherever possible, including development of green infrastructure to support the health and wellbeing of communities. This is a vital element of good planning that has been seriously totally neglected in the past , leading to a loss of sustainability and resilience in our communities! Wiltshire Council has suddenly, belatedly woken up to this principle and it will need a total change of the planning mindset. Can that be done? Providing high quality, well designed development, and ensuring full local community involvement in planning for significant new proposals. This is a Cross Comment No. Comments Officer Comments Issue Reference By very desirable objective. Again it is so far removed from past practice . that it is doubtful if it can be done. There has been no overall planning to ensure that developments take place together with the essential infrastructure in the past 15 years. In the Devizes Area, we We have extensive new housing but it has been built on an incremental basis without essential road improvements, without new green or open spaces, without local facilities (e.g. small shops, sub- post offices, community rooms). Utility services have not been planned and this has led to piecemeal, ad hoc reinforcements and endless disruptive roadworks. Each phase of development has been permitted on the basis that it is only a small increment and does not in itself warrant any major infrastructure works. Unless the whole of the infrastructure is planned in advance, the pattern will be repeated in the future. The essential principle should be that housing development cannot go ahead if the infrastructure is lacking. In addition, much of the housing developments have been of a high density that is suited to urban areas but not to more rural communities. It is not good enough simply to propose well designed development without recognising how it is to be achieved. As was the case for a previous key principle that linked out-commuting with detriment to infrastructure, the quality of design and full local community involvement are separate issues that should not be lumped together in this manner. The principle of full local community involvement and how it could be achieved requires explanation in the document. Providing the framework to deliver Neighbourhood Plans. It remains to be seen if the centralist tendency at Wiltshire Council can be overcome and local opinions can be accepted. It is feared that Neighbourhood Plans could will become a vehicle code for unfetteredand detrimental developments. Paras. 1.5 to 1.9 appear to be padding that adds nothing of value. One important possibility that has apparently not been considered and which could deliver the strategic requirements without compromise is the New Town concept. For instance, the The area around Ludgershall is close to a major primary road, the A303, has a rail head that connects into a main line between London and Salisbury, has no shortage of land and even has a small airfield at Thruxton. The strategic objectives, which will be reviewed in Having listed the key strategic objectives for Wiltshire in this Chapter it is odd that they are not view of consultation response, are directly linked clearly linked to specific delivery actions listed in Chapter 4. Again, it is an idealised and utopian to policies both in the area strategies and Chapter list which is of very limited value meaningless without a clear plan for achieving them. Apart 6. These show tangible ways in which progress from Objective 2, they are reasonable. Objective 2 "to address climate change" is woolly, can be made towards meeting the outcomes perhaps deliberately so, is probably not appropriate and is not a realistic key objective for identified. Lessons from the past are being drawn Wiltshire. It is apparently there for political reasons. Objective 9 "to ensure that infrastructure is on and that is a key reason that the economy 1562 in place to support our communities." is long overdue and there is much catching up to be done leads the strategy, to ensure that growth is based Chapter 3. Q22 from past neglect of infrastructure. Section 3.12 lists ten key outcomes as bullet points. It is fair on providing employment opportunities and that to state that these are important planning requirements to ensure the desired sustainable and these are supported by the appropriate number of resilient communities. The planners have conspicuously failed to deliver these objectives in the homes. It is accepted that in the past this was the past and communities are currently suffering the results of excessive housing developments other way round and led to too many homes, not without this infrastructure. If th is consultation exercise achieves nothing else whatsoever it enough jobs and consequent out commuting. should aim to ensure that this shameful history is not repeated in the next fifteen years. Infrastructure requirements are key and one of the first 3 policies in the document.

6.9 SO9: to ensure that infrastructure is in place to support our communities This is a very Agree on importance of strategic objective important objective but it It is notable that this section is devoid of useful content! It is an area relating to infrastructure. There will be a revised 1571 Question 3 that has been seriously neglected in the past while too much emphasis has been placed on version in the pre-submission draft of the house building, to the detriment of the health and well-being of our communities. Wiltshire Core Strategy. Cross Comment No. Comments Officer Comments Issue Reference By

A22: Bradford on Avon Town Council is concerned that the Government's emerging Localism Bill and the National Planning Policy Framework (July 2011 draft) are likely to weaken planning and environmental controls. This is likely to require further action by Wiltshire Council, on the basis that additional or enhanced policies may be required in the Core Strategy depending on the outcome of consultations on the NPPF. Wiltshire Council is requested to keep this under The Council will ensure that the Core Strategy is review and take action as and when required. Bradford on Avon Town Council is also 1591 compliant with the NPPF and the new Localism NPPF Q22 concerned over the Government’s proposal to relax the planning rules for change of use from Bill as and when these documents develop. business to residential. The Town Council is particularly concerned with the potential this proposed policy change might have to undermine one of the key –and much fought for – elements of the Bradford on Avon Community Area Strategy: “The loss of employment land in Bradford on Avon will not be supported...” (§5.5.5. bullet four). Wiltshire Council is similarly requested to keep this under review.

Graham Andrews is conscious that the Core Strategy will need to have regard to, and be able to adapt to, new/changed elements of policy in the emerging NPPF, which is currently a material consideration and will probably be in force by the time the Core Strategy is examined The Council will ensure that the Core Strategy is 1607 and adopted. In particular: · The 5 year + 20% deliverable land supply requirement; · The compliant with the NPPF and the new Localism NPPF Q22 presumption in favour of sustainable development and the circumstances in which it will apply; · Bill as and when these documents develop. The emphasis on economic growth; · The emphasis on viability/deliverability of developments and not placing onerous S.106 requirements.

Network Rail has been consulted by Wiltshire Council, on the Emerging Wiltshire Core Strategy Development Plan Document. Thank you for providing us with this opportunity to comment on this Planning Policy document. The following forms Network Rail’s consultation response: Upon the review of this document, Network Rail note there is no specific reference to the future electrification of the Great Western Main Line. Electrification presents huge opportunities for Wiltshire, it is better for the environment; electric trains emit around 2-35% less carbon per passenger than diesel trains, the new trains will have more seats and journey times will be cut. Electric trains are also cheaper to operate, require less maintenance and have lower energy costs. We note your aspiration for new stations at Corsham and Wootton Bassett; you will note that this is included in the Great Western Route Utilisation Strategy as a stakeholder aspiration. Network Rail would be happy to work with you on this. We do have an ‘Investment in Stations’ Electrification guide which details our process for new or reopened stations and explains how third party Comments noted. Electrification of the Great of Great funders and developers could work with Network Rail to develop their aspirations (copy Western Main Line is considered to be beyond Western Main attached). Any proposed development at sites adjacent to the railway should consider the the scope of the core strategy. Detailed 1636 Line. SO8 following points at design stage to eliminate any risk to the railway operations. It is guidelines on development adjacent to the Development recommended that all buildings be situated at least 2 metres from the boundary fence to allow railway line are noted, but this level of detail is not adjacent to the construction and any future maintenance work to be carried out without involving entry onto considered appropriate in the core strategy. railway line. Network Rail’s infrastructure. Where trees exist on Network Rail land the design of foundations close to the boundary must take into account the effects of root penetration in accordance with the Building Research Establishments guidelines. In the interests of safety any development adjacent to Network Rail land, developers may be requested to provide a suitable trespass proof fence (of at least 1.8m in height) adjacent to Network Rail’s boundary and make provision for its future maintenance and renewal. Additional or increased flows of surface water should not be discharged onto Network Rail land or into Network Rail’s culvert or drains; it is recommended that soakaways should not be constructed within 1 metres of Network Rail’s boundary. On development sites that are to be located on an area of land owned/previously under the ownership of Network Rail, then contact must be made to Network Rail’s Operational Portfolio Surveyor to understand further the implications this may have. Often these sites are Cross Comment No. Comments Officer Comments Issue Reference By sold and are the subject to a demarcation agreement which may include particular rights in relation to the safe operation of the railway and associated infrastructure. Network Rail would need to be consulted on any alterations to ground levels. No excavations should be carried out near railway embankments, retaining walls or bridges. The design and siting of buildings should take into account the possible effects of noise and vibration and the generation of airborne dust resulting from the operation of the railway. No work should be carried out on the development site that may endanger the safe operation of the railway or the stability of Network Rail’s structures and adjoining land. In the interests of safety, all new trees to be planted near Network Rail’s land should be located at a distance of not less than their mature height from the boundary fence. A comprehensive list of permitted tree species is available upon request for any landscaping proposals. Any lighting associated with the development (including vehicle lights) must not interfere with the sighting of signalling equipment and/or train drivers vision on approaching trains. The location and colour of lights must not give rise to the potential for confusion with the signalling arrangements on the railway. Children’s play areas, open spaces and amenity areas must be protected by a secure fence along the boundary of one of the following kinds, concrete post and panel, iron railings, steel palisade or such other fence approved by the Local Planning Authority acting in consultation with the railway undertaker to a minimum height of 2 metres and the fence should not be able to be climbed. I also enclose a link to Network Rail’s website; http://www.networkrail.co.uk/browseDirectory.aspx?dir=\RUS%2Documents&pageid=2895&root = This link provides access to Network Rail’s Great Western Route Utilisation Strategy (March 21) of which sets out the strategic vision for the future of the railway in this vital part of the railway network. It is hoped that this will be of use to the Council to keep you up to date with future aspirations for railway development in Wiltshire.

The reason that I've sent this in this format is because the web site that has been devised is impossible to log on to, having given 3 user names it rejected all. The other point I would like to bring to your attention is that site maintenance is being done over 6th & 7th August these last Comments noted. Every effort has been made to Consultation 1642 two days are vital, you should have said the closing date was 5th August ... seems a bit ensure the web version is accessible and Q22 process underhanded to me . Rather like this Core Strategy Consultation Document. I did look on the useable. web site but having wasted 3 hours trying to find what was being proposed I gave up and read James Gray MP column.

The opportunity to comment on the Wiltshire Core Strategy is welcomed, however it is noted that detailed assessment of the document will only be possible following the release of the evidence base and topic papers which support the strategy. It is recognised that site specific Comments noted. The Core Strategy process is allocation and justification is not appropriate at this time but will be addressed during the an iterative process. Evidence gathering in evolution of the strategy and through the forthcoming consultation process.The opportunity to ongoing throughout and therefore it is appropriate Consultation 1643 Q22 comment on the Wiltshire Core Strategy is welcomed, however it is noted that detailed for further changes and amendments to be made process assessment of the document will only be possible following the release of the evidence base to the Core Strategy proposals in light of new and topic papers which support the strategy. It is recognised that site specific allocation and evidence including consultation feedback. justification is not appropriate at this time but will be addressed during the evolution of the strategy and through the forthcoming consultation process.

We have been asked to submit our comments as part of the Wiltshire Core Strategy Consultation Document. It would be nice to really believe you are consulting us and that our Consultation 1645 Comments noted. Q22 views will make a difference to your plans - but looking at what has happened to Trowbridge in process the 22 years we have been in this area leaves me more cynical than ever. Cross Comment No. Comments Officer Comments Issue Reference By

These objectives are commendable - the Council will need to ensure that implementation matches the rhetoric There is mention of the re-development of Salisbury as part of the grand plan for economic growth - I fail to see how the Salisbury Vision delivers that plan. The ‘Vision' does nothing to enhance economic development and, in fact, hinders rather than helps the economy of Salisbury. There needs to be a serious review of precisely what the ‘Vision' is intended to achieve. Reducing the number of parking places in the City Centre will have a The SWCS is at a more advanced stage of South South 1662 serious adverse effect on the tourist income on which Salisbury is so dependent. If visitors can't production. The council is awaiting a binding Wiltshire Wiltshire park easily and cheaply (and that doesn't mean park and ride) they will move on to the next report from the planning inspectorate. venue. Wiltshire Council needs to ensure that public sector employees are not permitted to park in the City Centre, thereby freeing up hundreds of parking spaces for tourists and shoppers. The whole economy of Salisbury is hugely dependent on the Cathedral and Stonehenge. Anything actions the Council takes which detract from those 2 huge advantages will have an adverse knock-on effect to the rest of the City's economy.

Swindon Chamber of Commerce is supportive of amendments to the Core Strategy will need to comply with policy of the emerging National Planning Policy Framework. Recent Planning Inspectorate guidance confirms that this is a material consideration and will probably be adopted by the time the Core Strategy is examined. As the development industry is obviously being identified as a key driver of the Government ambitions for the nation’s economic recovery and job growth, the Chamber believes that the tenets of these documents should be strongly reflected in a positive and ambitious approach to planning at the local level. In particular the Swindon Chamber of Commerce believes amendments are needed to reflect: Strong recognition that provision for a buoyant business/development sector and policies to promote 1675 Support noted. Question 2 economic growth are implicit in the definition of sustainable development; The strong presumption in favour of sustainable development; The 5 year + 20% deliverable land supply requirement; The emphasis on maintaining viability/deliverability of developments; An emphasis on addressing cross-boundary issues. The Swindon Chamber would be supportive of more ambitious provision of development in line with the sustainable development provided for in the draft RSS. In particular the Swindon Chamber of Commerce has doubts that the reduction in housing from dRSS levels is adequately justified and supports the reinstatement of policy provision for 3000 houses west of Swindon. [background info for these comments is in the attached report.] Policy PS3 in the Local Transport Plan Car Parking Strategy states the factors that will be Core Policy 46. Unfortunately the management of public car parks has failed to take account of considered in setting parking charges; these Public car 1728 the factors described and is in danger of making Market Town centres unviable. The problem include the service role and strength of the local SO8 parks will be exacerbated by demanding private car parks make similar charges. economy, the convenience and quality of parking locations and parking charges in neighbouring areas.

Generally we are in agreement with the draft Core Strategy if the following points were improved. We agree that housing should be delivered with employment as the balance is not right at the moment. In the past there has been a lot more housing developments than there Comments noted. The strategy seeks to ensure have been new employment opportunities, this has resulted in more people commuting outside 1738 that appropriate infrastructure is delivered Question 2 of Chippenham for work, resulting in environmental, transportation and road congestion issues alongside new development. for now and the future. This imbalance needs to be addressed and initially it may mean more phasing of employment opportunities until employment and housing is more in balance resulting is less commuting. Cross Comment No. Comments Officer Comments Issue Reference By

1. Chapter 1 1.1. In para 1.4, I applaud the pious sentiments expressed, but note that no mention is made of enhancements to transport infrastructure to facilitate sustainable patterns of Noted. Transport model will be prepared for the development, and minimise the need to travel by private motor vehicle. 1.2. Also absent from main towns that will ensure that any final para 1.4 is any mention of optimising the use/facilitating the redevelopment/reuse of brownfield document is fully informed with respect to 1739 Chapter 1. Q22 sites. Given the number of existing and potential brownfield sites within the Corsham area, and transport infrastructure. The issue of previously over Wiltshire as a whole, the priority which should be given to their redevelopment should be a developed land will be highlighted more in the key principle. 1.3. In the second bullet point, the word "responsive" should be replaced by next version as this is an important issue. "proactive".

2. Chapter 3 2.1. The first paragraph under Spatial Vision states" By 2026 ... Market towns '" will have become more self-contained and supported by the necessary infrastructure, with a consequent reduction in the need to travel... .. " My comments below arise from the failure of the consultation Draft Core Strategy to set out the strategies and policies to achieve this laudable vision. 2.2. Strategic objectives 2.2.1. Wiltshire has a plethora of MOD sites, some of which are in use and contribute significantly to the local economy, some of which may become redundant before 2026, others of which are already redundant, and some of which are derelict. Agree and a specific policy related to ex-MOD 1741 There should be a strategic objective regarding the redevelopment of those sites which are Chapter 3. Q22 land will be included. already redundant or may become redundant. This is of particular significance to Corsham, where the Royal Arthur site has been derelict for a very long time, and where the Copenacre site is currently being marketed, and where the Rudloe site is also redundant, with no strong policy guidance as to the most appropriate and sustainable redevelopment for any of these sites. 2.2.2. The Strategic objectives should include "to prioritise and facilitate, for the benefit of the local community, the redevelopment of previously developed sites including redundant MOD sites"

1747 We support Core Strategy 38, 40, 42, 44, 45, 47, 48, 49, 50 and 51. Noted Q22

I am appalled that the above document was not readily available for the public as a hard copy. There are many like myself who cannot read numerous papers in a computer screen. I am also appalled that there was no reference made with in the above document to the 19 topic papers which are supposed to be the background to this consultation. Son how was anyone Comments noted. The Core Strategy document Consultation 1754 supposed to know on what you based this current consultation Again these topic papers were referred to the topic papers in paragraph 1.19 . Q22 process not readily available to the public and even more appalling was that they were not available in These were available online. Trowbridge Library. If you want a true consultation & want to be considered as a council "where everybody matters" then the public needs to be actively encouraged to take part in consultations. I do not consider you have achieved that. Cross Comment No. Comments Officer Comments Issue Reference By The proposed core policy 43 (transport and development) in the June 2011 consultation document indicates that the needs of public 8. Section 6.8 Sustainable transport 8.1. Corsham Chamber agrees that a sustainable transport transport users (including rail passengers) will system needs to be developed for Wiltshire as a whole, and for Corsham in particular. 8.1.1. It need to be considered as part of a required is noted that, in Core Policy 43 , the penultimate bullet point omits mention of safe access to the transport assessment (under the first bullet point). rail network. 8.1.1.1. It should be remembered that the rail network provides a sustainable It is considered that rail transport improvements transport alternative to the highway network, and its contribution reducing the county's carbon would already be covered by the phrase footprint should not be overlooked. 8.1.1.2. The last paragraph should be amended by inserting 'sustainable transport improvements' in the final "including rail transport improvements" before the words "and travel plans". 8.1.1.3. paragraph of core policy 43. References to Appropriately worded amendments relating to rail transport both for passenger and freight sustainable transport in paragraphs 6.8.8 and should be made to paragraphs 6.8.8 and 6.89. 9. Section 6.8.11 Transport Strategies 9.1. Core 6.8.9 would also cover rail transport. It is not 1784 Rail network SO8 Policy 45 is highway-centric. 9.1.1. It fails to take into account the potential to provide integrated considered that core policy 45 (transport transport measures which include rail transport. 9.1.2. By concentrating on the Principal strategies) is highway-centric: the core policy Settlements, it completely overlooks the existing and potential access to the rail network which specifically refers to 'helping to reduce reliance on is available in many of the Market Towns, including Corsham, Melksham, and Westbury. 9.1.3. the private car', and to 'enhanced public transport If the proposed allocations at Showells Farm are implemented, it would make sense not only to services and facilities'. The proposed core policy dual the A35 Chippenham Bypass, but also to construct a rail passenger and freight 48 makes specific reference to Corsham, interchange at Thingley junction. 9.1.4. Packages of integrated transport measures should be Melksham and Wootton Bassett rail stations. The identified for all towns having a railway station, or the potential for a railway station to be re- Westbury Area Strategy highlights the excellent opened or created, such as Corsham and Thingley. rail connectivity of the town. The proposed core policy 45 focuses on the Principal Settlements because these settlements will see the greatest levels of growth during the plan period. 10. Appendix 1. Glossary of terms 10.1. Although there is a definition of "Greenfield site", there Noted. The glossary will be updated in the next 1785 is no definition of "Brownfield site". The Glossary should be amended to include the standard Glossary Q22 draft of the Core Strategy definition of a brownfield site. The terminology used to encourage a sustainable approach to development in the strategies of adjacent LPAs is inappropriate, neither does it reflect the past history of joint working, on both the Structure Plan and the West of Swindon Study, between the former Wiltshire County Council and Swindon Borough Council (and Thamesdown Borough Council before that), since the 1970s. Where there are cross-boundary issues these are normally discussed between officers in the course of the preparation of their respective DPDs. In the case of Swindon Borough the principle of reducing commuting as a means of increasing sustainability has been explicit in the preparation of its Core Strategy. It is therefore inappropriate for an adjacent council is request that the Borough Council should adopt this approach. The previous The housing and employment requirements for identification of areas within Wiltshire but adjacent to Swindon was made in association with both Swindon and Wiltshire have been developed and with the agreement of Wiltshire Council and the previous authorities and was found to be on a consistent basis, and both authorities have sustainable, with the potential to reduce commuting from more distant parts of Wiltshire. It was advised the other on the approach. Both seek to hardly a case of “relying on Wiltshire” to meet Swindon’s housing needs. These areas are no minimise cross-border commuting. 1787 Chapter 2. Q22 longer required following a reduction in Swindon’s global housing requirements and the intended abolition of the dRSS. The corollary of para. 2.7, of course, is that Wiltshire has not There are both benefits and disbenefits to the been able to meet the employment needs of its residents, and the Wiltshire Core Strategy economy of the proximity of the large urban needs to ameliorate this situation, as is recognised in para. 2.15 and strategic objective 1. centre of Swindon, due to the relative location of Indeed, one of the outcomes of strategic objective 1 is that “ out commuting from Wiltshire will income and expenditure. have been addressed” . Therefore, the objective of reducing Wiltshire’s reliance on Swindon for job provision is supported. However, the planning needs of areas are not limited to administrative boundaries, and it is to be expected that larger urban areas will have a larger and broader employment base that will attract workers from an area wider than an individual local authority. Paragraph 2.7 recognises this in highlighting Wiltshire’s strong links with large urban centres – links that benefit Wiltshire and its residents. It is issues such as these that leads the Government to include the duty to co-operate in the Localism Bill – although there has been a long history of Swindon and Wiltshire planning authorities successfully doing this Cross Comment No. Comments Officer Comments Issue Reference By anyway. In terms of sustainability issues, it needs to be recognised that there is also considerable commuting patterns that need to be addressed within Wiltshire, such as in the area between Chippenham and Warminster, It is noted that para.2.7 complains that Wiltshire “suffers from……loss of expenditure through people travelling for shopping and leisure purposes to these large urban areas ”, whilst para.2.11 says that “ out-commuting may have a beneficial effect on the local economy through income earned outside the area being spent in Wiltshire.” These statements seem to be contradictory.

3.2 - This section should include an objective ‘T o protect and promote the distinctive identity of our communities, settlements and landscapes’ . - Local distinctiveness and particular character is what makes so many of our towns, villages and landscape so special. If not appropriately guided, change and development pressure can erode local distinctiveness. It is vital that where change occurs that this fosters and enhances valued local character and distinctiveness. 3.2 - Suggest add to objective 4 – ‘to help build resilient and self sufficient communities’. - Local jobs and business opportunities supported by appropriate infrastructure can help people to avoid travelling, reduce food miles and help foster stronger communities. 3.5 - This section should include a point promoting local markets for local produce, encouraging local food production, and seeking the retention, management, enhancement and extension of landscape features that produce food and drink. - In a rural area such as Wiltshire there is significant potential for local produce to significantly reduce food miles, and for existing landscape features such as allotments, hedgerows (blackberries, plums, sloes, elderflowers, elderberries) and orchards to have contributed local produce. This is in addition to the potential of the farming sector to further develop local produce markets. 3.7 - We welcome the support for neighborhood plans Strongly agree and the whole of the WCS is being adding detail to the overarching policies in the Core Strategy. - Local people are often most produced to reflect that. That is the reason for able to decide what is important to their community, and what its priorities are for the future. 3.8 detailing the Area Strategies which pick up - First bullet: Strengthen wording to read: ‘ Wherever possible, development will be directed 1791 spatially distinctive issues and introducing new Chapter 3. Q22 away from our most sensitive and valuable natural assets….’ - In order to ensure no net loss of polices on design and local landscapes. The next important species & habitats, it is vital that we protect them from inappropriate development. version will be checked to ensure it safeguards This is in line with PPS 9. 3.8 - Second bullet: This should include reference to the National and delivers local distinctiveness as suggested. Biodiversity Action Plan as well as the Local Biodiversity Action Plan. - To give added weight to this statement. 3.8 - Additional bullet point needed: ‘The important and characteristic landscape settings and green spaces in our towns and villages will have been conserved and enhanced’ The Core Strategy should be checked to ensure that these points are adequately covered in the policy on biodiversity and landscape. - Green and open spaces and landscapes are vital to the character of many of our towns and villages, and access to them has been proven to improve mental wellbeing. These landscapes are frequently under pressure from developers and/or urban fringe activities. It is vital that the delicate balance between green and built is maintained and enhanced. 3.9 - These bullets should, in addition to reference to BUILT heritage, include reference to the need to conserve and enhance historic landscapes and natural features of heritage importance. The Core Strategy should be checked to ensure that these points are adequately covered in policy. - Wiltshire’s heritage includes not only built features but also historic landscapes and historic and man-made landscape features, including e.g. Traditional Orchards, hedgerows, field patterns, views and vistas, veteran trees, ponds etc. These are vital features that must be protected, managed and enhanced. Cross Comment No. Comments Officer Comments Issue Reference By I write to register my views with regard to the Wiltshire Core Strategy Consultation Document issued in June. I broadly accept the approach adopted by Wiltshire Council, which is very much in line with the Government's Localism agenda. It is right that local people represented by their councillors should take their own decisions about what they would like their environment to look like in the years ahead. I believe I represent the vast majority of my constituent's views in saying that I believe that our environmnent in the years ahead should look very much like it does today. I do not subscribe to the 'grow or die' notion, and nor do I accept the need for a significant urban extension of the kind which is proposed in the document. Wiltshire currently enjoys a broad balance between housing and employment, we do have the 620th lowest unemployment by constituency in the UK. We would increase either the number of houses or indeed the number of employment opportunities at our peril. We all enjoy our semi-rural and market town way of life and owe it to the future generations to seek to preserve it. Outside our relatively small and pleasant market towns we have an overwhelmingly agricultural and military environment and relatively low industrial or manufacturing activity. It seems to me that we ow it to our descendants to seek to preserve the balance. For that reason I strongly oppose the very large number of houses, which are proposed to be built in the green belt surrounding Chippenham, Noted. The majority of these comments concern Chippenham as well as the relatively smaller number proposed for Malmesbury. It seems to me Wootton site allocations around Chippenham and Swindon Number of 1794 Q22 that Chippenham as a town has reached its natural size with a fairly sensible balance between Bassett & and these comments have been passed on to the Issues population and employment. I, therefore, do not support the proposed new industrial site on the Cricklade relevant officer. Showell end of the town, which would seem likely to me to be likely to lead to further development south of Chippenham. I also strongly opposed the proposed housing to the east and north of the town. I very much support the long-standing campaign to prevent Swindon expanding westwards. The towns of Cricklade, Purton, Lydiards and Wootton Bassett must preserve their identities, and the rural buffer between the two is absolutely vital to the end. I do accept that we have a need for low cost local housing, but do not believe that the creation of extensive executive-style homes of the kind proposed in the document would lead to any alleviation of homelessness so much as an increased encouragment of outer communities. Affordable housing would be much better provided on brownfield sites within the towns where they can be found, despite developers' reluctance to make the necessary investment to do so. I very much hope that you will therefore take these general views into consideration in re-drafting the Core Strategy. I simply do no accept the necessity for our urban towns and villages to expand in the way that your document currently proposed. I would happily expand on these views in detail if you wished it, but would be grateful if you would accept them as a general opposition to the broad thrust of the proposals in the document. The proposed core policy 43 (transport and development) in the June 2011 consultation document indicates that, for development where a Core policy 42 - We suggest that this policy must promote pedestrian and cycle priority over the transport assessment is required, applicants Pedestrians 1801 car in new developments. - In order to ensure the promotion of sustainability of new should demonstrate that "consideration has been SO8 and cyclists development. given to the needs of all transport users (where relevant)" according to a hierarchy, with pedestrians and cyclists both above private cars in the hierarchy. Cross Comment No. Comments Officer Comments Issue Reference By Draft Topic Paper 14: Site Selection Page 69 - 71 - We agree that the promoters of the land between the Holt Road and Woolley Street have underplayed the capacity of the site, and we are very concerned at the potential impacts that this would have on existing adjacent communities and on the town as a whole. - The roads and infrastructure of the town simply cannot take the levels of development that could be accommodated by this 7.8ha area of land. June 2011 Consultants surveying in the field adjacent to Crown Court advised that they discovered 10 different species of bat in this location. Local community surveys support this finding. Barn owls are regularly seen hunting over this field. Lapwings are regularly seen in the adjacent field. A Great Crested Newt was found in a pond adjacent to the field by Crown Court in April 2010, showing the potential for populations in the area. This was reported to the Wiltshire Record Centre. These findings should be highlighted in the site assessment. The Adopted Conservation Area Character Assessment: states the importance of rural character Concerns noted. This site is not proposed as a Bradford on and views to the Conservation Area. Highlights key views from Woolley Street across the field strategic site in Bradford on Avon. Consideration Avon 1803 adjacent to Crown Court to Salisbury Plain, and from the public right of way across the field CP9 has been given to the site as an alternative site Site Selection Site selection back to Crown Court. The site assessment should state that that local residents of the many for development but it is not proposed for it to be process terraced cottages have no alternative to on street parking on Woolley Street and Woolley allocated in the core strategy. Terrace. The adjacent houses on Woolley Street have habitable rooms directly onto the edge of the carriageway. Many houses and paths exit directly onto the street or onto very narrow substandard pavements. These impacts should be highlighted in the site assessment. Due to the narrow geometry of the streets, and lack of ability to widen, this creates what are in effect single track roads with limited and offset parking spaces. The assessment should state that Woolley Street and Woolley Terrace cannot absorb any significant additional traffic without seizing up and posing further threats to the safety of residents, pedestrians and cyclists and to the residential amenity of the adjacent terraced cottages. This lack of capacity and these impacts should be highlighted in the site assessment. We agree with the findings of the recommendations, but suggest the addition of potential impact on residential amenity, important views and vistas, and on wildlife habitats and protected species. The Parish Council broadly welcomes the opportunity to comment and share in the future shaping of Wiltshire. This comment represents the corporate views of the Parish Council and 1835 Noted Q22 includes comments of local residents who attended a Parish meeting at which the strategy was discussed.

The Parish Council broadly welcomes the vision outlined in the Consultation Document. This 1837 comment represents the corporate views of the Parish Council and includes comments of local Noted Q22 residents who attended a Parish meeting at which the strategy was discussed.

Particular issues in rural areas are recognised in the Transport Topic Paper, which states for example that "In a rural area such as Wiltshire, encouraging modal shift or reducing travel demand can be difficult" (para 6.9) and which This comment represents the corporate views of the Parish Council and includes comments of recognises the "reduced commercial viability of local residents who attended a Parish meeting at which the strategy was discussed. Core Policy public transport which, especially in rural areas, 48: transport The Core Strategy does not recognise the special requirements of rural areas 1841 cannot match the flexibility of the private car" Rural areas SO8 such as Winsley, which, though served by a regular bus route, is vulnerable to this service (para 6.1). The proposed core policy 42 being withdrawn. The public bus and train services must be safeguarded and expanded. We (Sustainable transport) in the June 2011 would encourage more ‘joined-up’ public transport consultation document states that "the council will use its planning and transport powers to help reduce the need to travel" and that this will in part be achieved by "promoting sustainable transport alternatives to the use of the private car". Cross Comment No. Comments Officer Comments Issue Reference By

West of Swindon Although the vision of reducing out-commuting by increasing local Noted. However it is considered that promoting employment is supported, particularly avoiding predominantly car based travel, this should not sustainable transport is likely to be a positive be adopted as an inflexible prerequisite to development where it would unduly hinder the benefit to the economic growth that the Core establishment and operation of businesses or discourage the inward investment which can Strategy is committed too. drive economic recovery. A more appropriate ambition should be promoting sustainable Comments are noted also regarding West of development in Wiltshire, including reducing car-based commuting while not compromising Swindon development. All policy decisions are economic recovery. The Swindon Chamber of Commerce also opposes the cancelling of the indeed based on a robust evidence base that Economic Wootton 1874 dRSS provision for development west of Swindon as this does not reflect a sensible approach includes not only technical reports, but Development Bassett to planning for sustainable development. We believe that development on land in closest consultation responses including the wishes of proximity to a Principal Urban Area which experiences high levels of inwards commuting from local people, many of whom are opposed in Wiltshire is still a valid and sound approach to addressing travel to work imbalances. The Core principle to the development suggested. It is the Strategy must be robustly supported by the evidence base and elimination of development Core Strategy’s difficult task to balance the options of the dRSS must be a matter which is independently assessed in an assessment of sometimes conflicting needs of economic growth, development option by Wiltshire’s Strategic Environmental Assessment. [background info for protection of environmental assets and wishes of these comments is in the attached report.] the community.

West of Swindon The Swindon Chamber of Commerce, for reasons elaborated on in the attached document, is particularly concerned that the Wiltshire Council effectively proposes adopting the unsound spatial strategy provisions of the Revised Swindon Core Strategy in setting development provisions for land in Wiltshire which is located immediately west of Swindon. The Swindon Chamber of Commerce believes that, in its current form, the Revised Swindon Core Strategy is fundamentally unsound. The Swindon Chamber of Commerce therefore opposes the apparent reliance of the Wiltshire Core Strategy on the Revised Swindon Core Strategy March 2011 to set its key Spatial Policy with respect to land west of Swindon, rather than the more robust provisions of the draft Regional Spatial Strategy for the South West (RSS). The Swindon Chamber has a particular interest in development at Swindon, and in representing these interests opposes any reduction in provision of development in Wiltshire adjacent to Swindon. The Swindon Chamber of Commerce believes that land adjacent to Noted. The Council is bound to base its Core Swindon is a highly sustainable location for growth of both employment and housing , and Strategy policies firmly on a strong evidence therefore requests that as a minimum the development provisions of the dRSS be reinstated, base, and this explains and justifies the policies including provision for 3000 additional dwellings on land west of Swindon, for reasons set out in referred to independently of any other planning its representations. The Swindon Chamber of Commerce completely reject the notion that the document. In the case of drawing up policies in Wiltshire Core Strategy can adopt the inward looking development provisions of Swindon North Wiltshire proximate to Swindon, we have Development Wootton 1876 Borough Council as a satisfactory approach to cross-boundary planning. We firmly believe that worked closely with the Borough Council and West of Bassett this approach is an unsound basis for implementing the new responsibilities of local have also undertaken research far more recent Swindon. government to take a justifiable approach to strategic planning under the emerging planning that any underpinning any other document (e.g. policy regime which is necessary in the absence of Regional Strategies. Wiltshire Council do the RSS). We are confident that the polices not appear to support the proposed policy option with strong evidence base justification. In proposed are therefore founded on very robust contrast, the provisions of the dRSS were soundly justified, as confirmed by robust public evidence. Please note comments to 550849 examination. The emerging draft National Planning Policy Framework July 2011, which the (previous comments from same respondent) Planning Inspectorate indicate should be a material consideration, will re-impose a duty on local authorities to cooperate, while fulfilling their other planning responsibilities (see paragraphs 44 to 47). The Swindon Chamber of Commerce believes that the Wiltshire Core Strategy should not deviate from the provisions of the dRSS, until adequate evidence base justification is provided, particularly provision for development on land west of Swindon. The dRSS aimed to deliver sustainable development, including a focus on regeneration at Principal Urban Areas, which justified provision for development west of Swindon in Wiltshire to complement other development at sustainable locations in both Wiltshire and Swindon. The mere existence of a local authority boundary should not be used by Councils as an excuse to overrule a commonsense approach to planning for sustainable development. [background info for these comments is in the attached report.] Cross Comment No. Comments Officer Comments Issue Reference By

I was unable to include the follwoing with my letter of the 4th of August as I was not sure of certain information. This was and and I know understand that Lord Radnor is the owner of land adjacent to Odstock Hospital (that is if there is insufficiant land for building within the Hospital). Comments noted. The proposed core policy on He is also the onwer of the A.O.N.B site with the Nunton Village. My letter of the 1.04.08 landscape indicates that 'development should referes. Adjacent land to the Hospital is a "lower grade! and would appear to satisfy your protect, conserve and where possible enhance matters if concern re providing the hospital housing. No infringement on the Local landscape character', and that 'Proposals for 1884 Plan,Countryside Policies. Reduce Greenhouse Gases, move travel time and distances. Skilled development within or affecting the Areas of AONB SO5 staff, in the event of disasters, aircraft, railway and serious highway crashes, on site, almost, if Outstanding Natural Beauty (AONBs), shall have needed. I seem to be doing nothing but apologising for the disjointed evidence. The matters regard and evidence is important to me and I hope yourselves, I hate building on and destroying this to the relevant Management Plans for these A.O.N.B, "beautiful landscape". It is a perminant requirement of your strategy and the "Local areas'. Plan, Countryside Policies", included I know. Please find enclosed a copy of page 69 of the above "Policies" relevenat. Thank you, I am in my 90th year you know!

The priorities for infrastructure are set out in Core Policy 3, the individual area strategies and in the 1886 Infrastructure - Developer funds - what the priorities are. Infrastructure Delivery Plan, which will be Question 3 published to accompany the pre-submission draft of the Wiltshire Core Strategy. The Authority has been involved as a statutory consultee in the preperation of the seperate SWCS which is currently going through its Examination hearing sessions. Wiltshire Council's intention that the County Wide Wiltshire Core Strategy will, once adopted, "replace" the SWCS (paragraph 1.13) is noted. However, it is unclear from the current consultation document (e.g. paragraph 1.13, Section 5.2 and Section 5.14) weather the spatial strategies and associated policies for Salisbury and surrounding areas contained within the draft SWCS will be simply rolled forward into the WCS, or whether some of the issues will be re-opened for debate? There are aspects and specific policies within the draft SWCS that Authority supports and would wish to see retained within the WCS. The proposed housing requirements for South Wiltshire and teh Southern Communities Area, for example, have been developed following extensive The issue of the SWCS policies will be clarified SWCS research and consultation and it would seem logical to utilise this evidence base in developing for the pre-submission draft core strategy. The policies. the WCS. Linked to this, the Authority would welcome greater clarification over the Council's justification for the proposed Wiltshire-wide Housing 1900 approach to housing in the Wiltshire-wide plan area, with the consultation document stating that housing numbers is set out in the Housing SO5 numbers. New "around 37'000 new homes" are proposed up to 2026 (para. 3.6). The Authority is aware that Requirement Technical Paper. Consideration will Forest Wiltshire Council is currently proposing a housing figure approximately 20% lower than the be given to adding reference to the New Forest National Park. Secretary of State's Proposed Changes to the South West Regional Spatial Strategy as part of National Park in the landscape policy. the seperate SWCS Examination sessions, and teh approach in the rest of the County should be clarified. The Authority would also strongly recommend that Core Policy 15 - New Forest National Park of the draft SWCS is carried forward into Chapter 6 of the WCS (e.g. Core Policy 34) to ensure that it becomes a key strategic objective for Wiltshire as a whole, rather than become a place-specific policy conatined within the South Wiltshire Community Area Strategy section of the WCS. Core Policy 34 currently referes to proposals that could impact on the setting of, and views from ot to, the AONB and the Authority would welcome a similar recognition in this policy potential impacts on the National Park. This is specifically relevant given the statutory duty referred to below.

Core Policy 48 - Strategic transport network a. Insert "Westbury rail station" as the 3rd bullet The stations identified in the proposed core policy point in the list of stations. b. The Core Strategy relies heavily on a comprehensively 48 (strategic transport network) are priorities for Westbury 1906 coordinated and integrated infrastructure especially in terms of road and rail communications. improvement, but this does not preclude SO8 station This is particularly true for increasing the attraction of businesses and tourists to Westbury. improvements at other stations, such as Westbury station is a vital part of any integrated transport infrastructure in West Wiltshire. Westbury. Cross Comment No. Comments Officer Comments Issue Reference By The Authority is please to note that reference has been made to the fact that part of the New Forest National Park lies within Wiltshire (paragraph 2.2). National Parks have been confirmed by Government as having the highest protection in relation to landscape and scenic beauty (PPS7) and Section 62 of teh Environment Act 1995 places a duty on all relevant authorities (including neighbouring planning authorities) to have regards to the two statutory National Park purposes in making decisions which could impact on National Parks. The two Park purposes are: To conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park; and Tp promote opportunities for the public understanding and enjoyment of the special qualities of the National Park. Specific acknowledgement of this important statutory duty should be made within the WCS. The Authority is also pleased to note that reference is made to the fact that the area of Wiltshire wthin the National Park falls under the jurisdiction of the National Noted. The New Forest National Park should be 1908 Park Authority for planning purposes (paragraph 2.8). The failure to clearly acknowledge this is properly referenced throughout the document and New Forest Q22 in the preperation of the seperate SWCS has caused some confusion within the Wiltshire this will be amended for the next draft. Communities of the National Park and for clarity it would be helpful if the area of the county covered by the National Park (and therefore outside the scope of the Core Strategy) was shown on any inset maps (e.g. Map 2.1 and Map 4.1). It is noted, for example, that AONBs have been identified on the Key Diagram, but not the New Forest National Park. It is important that the Key Diagram shows the interrelationships between Wiltshire and its surrounding areas to give a more 'spatial approach' and more accurately ref;ect the statutory duty placed on neighbouring authorities to have regard to the impacts on the National Park as outlined above. The Authority would recommend that the geographical extent of the New Forest National Park is accurately illustrated on the Key Diagram and it is clarified on the Diagram that the area within the National Park is not covered by the WCS. The Authority has been involved as a statutory consultee in the preparation of the separate South Wiltshire Core Strategy which is currently going through its examination hearing sessions. Wiltshire Council's intention that the county-wide Wiltshire Core Strategy will, once adopted, 'replace' the South Wiltshire Core Strategy is noted. However, it is unclear from the current consultation document (paragraph 1.13, section 5.2 and section 5.14) whether the spatial strategies and associated policies for Salisbury and surrounding areas contained within the draft South Wiltshire Core Strategy will be simply rolled forward into the Wiltshire Core Strategy, or whether some of the issues will be re-opened for debate? There are aspects and specific policies within the draft South Wiltshire Core Strategy that the Authority supports and would wish to see retained within the Wiltshire Core Strategy. The proposed housing Policies already tested and found sound in the requirements for South Wiltshire and the Southern communities area, for example, have been South Wiltshire Core Strategy will remain in developed following extensive research and consultation and it would seem logical to utilise this place, although where there is some need for a evidence base in developing the Wiltshire Core Strategy. Linked to this, the Authority would minor adjustment to ensure the documents are Relationship 1912 welcome greater clarification over the Council's approach to housing in the Wiltshire-wide plan SO5 Q22 merged properly this will take place. The with SWCS area, with the consultation document stating that 'around 37,000 new homes' are proposed up comments regarding the placement of the New to 2026 (para 3.6). The Authority is aware that Wiltshire Council is currently proposing a Forest National Park in policy are noted and will housing figure approximately 20% lower than the Secretary of State's Proposed Changes to the passed on the relevant officer. South West Regional Spatial Strategy as part of the separate South Wiltshire Core Strategy Examination sessions, and the approach in the rest of the County should be clarified. The Authority would also strongly recommend that Core Policy 15 - New Forest National Park of the draft South Wiltshire Core Strategy is carried forward into Chapter 6 of the Wiltshire Core Strategy (e.g. Core Policy 34) to ensure that it becomes a key strategic objective for Wiltshire as a whole, rather than a place-specific policy contained within the South Wiltshire Community Area Strategy section of the Wiltshire Core Strategy. Core Policy 34 currently refers to proposals that could impact on the setting of, and views from or to, the AONB and the Authority would welcome a similar recognition in this policy of potential impacts on the National Park. This is specifically relevant given the statutory duty referred to below. Cross Comment No. Comments Officer Comments Issue Reference By The proposed core policy 1 (settlement strategy) seeks to direct development to the most sustainable locations (the Principal Settlements and Market Towns). However, a modest level of Core Policy 42 Susta inable Transport and Core Policy 43 Transport and Development We development is considered appropriate at Local would like to take the opportunity of pointing out that these policies as written, conflict with other Service Centres, in order to safeguard the role of policies relating to developments in villages and need to be reconsidered. For example: Core Conflict of these settlements and support the more rural Policy 42 refers to ' planning developments in accessible locations' and ' promoting susta inable transport communities. A limited level of development is transport allernati ves to the use of the private car' . Neither of these statements are consistent policies with considered appropriate at Large and Small 1919 with developing in rural areas as rural locations could be classed as inaccess ible and due to strategy to SO8 Villages in order to help retain the vitality of these the lack of public transport there is reliance on the use of private cars. Core policy 43 says 'New allow communities. The overall settlement strategy is development should be located and designed to reduce the need to travel and to encourage the development nonetheless considered to be in line with the aim use of sustainable transport alternatives' This statement is inconsistent with developing in rural at villages of promoting sustainable transport alternatives to areas where sustainable transport alternatives are limited. We ask the Council to look again at the use of the private car, since it indicates that the issues raised above. the most significant levels of development should take place in the locations which will be most accessible by public transport (the Principal Settlements and Market Towns).

Core Policy 27: In line with the Authority's comments above, whilst it is noted that the proposed Core Policy on renewable energy refers to potential impacts on landscapes, particularly in and Consideration will be given to adding reference to around AONBs, Green Belts and World Heritage Sites, reference has again not been made to the New Forest National Park in the policy on New Forest 1920 the potential impacts on the adjacent New Forest National Park. In line with the requirements of SO2 standalone renewable energy installations in the National Park. paragraph 14 of PPS22 (Renewable Energy) and Wiltshire's Council dut to have regard to pre-submission draft core strategy. impacts on the National Park in making decisions that could affect it, this policy should be amended accordingly.

The Authority is pleased to note that reference has been made to the fact that part of the New Forest National Park lies within Wiltshire (paragraph 2.2). National Parks have been confirmed by Government as having the highest protection in relation to landscape and scenic beauty (PPS7) and Section 62 of the Environment Act 1995 places a duty on all relevant authorities(including neigbouring planning authorities) to have regard to the two statutory National Park purposes in making decisions which could impact on National Parks. The two Park purposes are: To conserve and enhance the natural beauty, wildlife and cultural heritage of the National Park; and To promote opportunities for the public understanding and enjoyment of the special qualities of the National Park. Specific acknowledgement of this important statutory duty should be made within the Wiltshire Core Strategy. The Authority is also pleased to note that reference is made to the fact that the area of Wiltshire within the National Park falls under the jurisdiction of the National Park Authority for planning purposes (paragraph 2.8) The The support is noted, and the Key Diagram will be 1922 Chapter 2. Q22 failure to clearly acknowledge this in the preparation of the separate South Wiltshire Core amended. Strategy has caused some confusion within the Wiltshire communities of the National Park and for clarity it would be helpful if the area of the county covered by the National Park (and therefore outside the scope of the Core Strategy) was shown on any inset maps (e.g. Map 2.1 and Map 4.1). It is noted, for example, that AONBs have been identified on the Key Diagram, but not the New Forest National Park. It is important that the key diagram shows the interrelationships between Wiltshire and its surrounding areas to give a more 'spatial approach' and more accurately reflect the statutory duty placed on neighbouring authorities to have regard to the impacts on the National Park as outlined above. The Authority woudl recommend that the geographical extent of the New Forest National Park is accurately illustrated on the Key Diagram and it is clarified on the Diagram that the area within the National Park is not covered by the Wiltshire Core Strategy. Cross Comment No. Comments Officer Comments Issue Reference By The Authority welcomes the acknowledgement within Section 3 of the policy that recreational pressures that can arise on the New Forest SPA from development in Wiltshire. This is supported by the evidence base that the Authority has helped to developed in the Footprint Ecology Report Chaning patterns of visitor numbers within the New Forest National Park with particular reference to the New Forest SPA (2008). The Authority is currently working with Natural England to develop this evidence base further. Whilst the Authority is encouraged to see that delivery of mitigation on the New Forest SPA is identified in bullet point (ii), it is noted that the HRA for the draft Core Strategy states that further details are required and maked Wiltshire Council will work closely with the New Forest 1923 recommendations in this respect, these however, do not appear to have been addressed in this NFNPA in implementing the requirements of this SO5 SPA consultation document. The Authority also welcomes reference to the consideration of SANGs policy. (bullet point iii), but it should be noted that no work has been undertaken to establish whether such methods will deliver adequate mitigation / avoidance and be applicable to the New Forest context - the approach is therefore not supported by relevant local evidence. The Authority would welcome the opportunity to be involved with discussions between Wiltshire Council and Natural England with a view to developing Core Policy 33 further. I trust the above is the assistance in highlighting the New Forest National Park Authority's views on the emerging WCS DPD and should you wish to discuss any of the above, please do not hesitate to contact me.

I enclose a copy of the report which the White Horse Alliance commisioned from the landscape consultant Alan James. As I expect you know, the final text of the report was prepared after discussion between Mr James and your landscape office Maxine Russell. We welcome the way that supporting documents to the Core Strategy, such as Environment Topic Paper 5, on Comments noted. It is intended that the policies environment and biodiversity, acknowledge that areas of special landscape such as the Special relating to the Special Landscape Areas will 1926 Wellhead valley may need continuing protection in the final Core Strategy. It is good that the Landscape SO5 continue to be saved and will be subject to review Wellhead Valley is singled out for special mention in this way. We cannot however welcome Areas. by the emerging Wiltshire Landscape Strategy. much else in the draft core strategy. It is not a coherent plan for the development of the county in the period to 2026. we do not proposed to catalogue the extent of the failure at this stage. The general can be be tested by the particular example of plan policies to Westbury and the environmental constraints to development proposals set out in the plan.

Generally the main Wiltshire Core Strategy Document is well - written although verbose and repetitive at times. The " How to comment on this Document " section needs to be right at the Noted. The how to comment section will be 1955 Chapter 1. Q22 beginning. It would be useful to have the Chapter Number at the bottom of each page in the moved to the beginning in the next version. grey strip with the Page Number.

Well written general information on Wiltshire. The employment breakdown chart (Page 13) is The points have been noted. Full analysis of the good. For Page 15 there needs to be a definition of the various categories of legend . I could deprivation in Wiltshire can be found within the 1956 Chapter 2. Q22 not distinguish between mid-blue and dark blue of last two categories 2.8. Line 5 should be Deprivation in Wiltshire report (available at amended to read "town or village centre enhancements" www.intelligencenetwork.org.uk).

3.11 Key Outcomes need to be more specifically described e.g. Improving rail services to Outcomes are deliberately broad and the market towns and installing more cycleways between towns. For Outcome 4, railways are used conditions should be delivered through to cross rural areas to link towns not as a mode of transport within them. How will these 1957 development proposals which are managed Chapter 3. Q22 outcomes be achieved? 3.12 Key outcomes need to state how they will be achieved. For 7, through the subsequent polices of the Core who will decide whether an infrastructure service or facility is no longer required? 3.13 In view Strategy. of climate changes, no new develop should take place at all where there is a risk of flooding.

Well written general information on Wiltshire. The employment breakdown chart (Page 13) is 1960 good. For Page 15 there needs to be a definition of the various categories of legend . I could Chapter 2 Support Noted, amendments will be considered. Melksham not distinguish between mid-blue and dark blue of last two categories 2.8. Line 5 should be Cross Comment No. Comments Officer Comments Issue Reference By amended to read "town or village centre enhancements" To which part of the Wiltshire Core Strategy Consultation Document does your comment relate? 3 Chapter: Question: Paragraph: Community Area: Comments: 3.11 Key Outcomes need to be more specifically described e.g. Improving rail services to market towns Wiltshire Council continues to work with rail and installing more cycleways between towns. For Outcome 4, railways are used to cross rural providers to increase services across Wiltshire 1960 areas to link towns not as a mode of transport within them. How will these outcomes be Chapter 3 Melksham and better links within Wiltshire remain a priority achieved? 3.12 Key outcomes need to state how they will be achieved.

For 7, who will decide whether an infrastructure service or facility is no longer required? 3.13 In view of climate changes, no new develop should take place at all where there is a risk of flooding. Chapter: 4 Question: 1 Paragraph: Community Area: Comments: There needs to be more consultation with the local councils re the Settlement Strategy, to agree in which category settlements should be placed. The allocation of settlements appears to have been done without much knowledge of some of them. Bowerhill for example, rather than being assumed to form part of Melksham Town, which it does not, should be placed in the Local Service Centre category as it meets the criteria. It is difficult to understand why large villages are having their boundaries retained whereas smaller villages are not. Please explain. While the Settlement Strategy mentions pockets of deprivation, most of the document involves giving facts or aspirations without saying how they can be achieved Chapter: 4 Question: 2 Paragraph: Community Area: Comments: The Chapter of Delivery Strategy is difficult to understand and at times seems muddled, especially page 29! Melksham is not seen as a Principal settlement and yet is deemed a "Key strategic location" for employment. Is this to address the perceived inbalance between too much housing and too little employment to date? Are there differing key locations for employment as opposed to housing? Surely the idea is to have both housing and employment under the same category to make areas more sustainable? I thinks it seems muddled because of word-play/descriptions of "key strategic" and strategic" Which is Melksham, key strategic or strategic or neither and why? It is unclear who will prepare the master plans and what role local councils are to be given in either the master plans or the neighbourhood plans. Map Pg 28- From this it looks as though the Local Service Centres are out in the middle of the countryside. The names of these centres should be put on the map This section would benefit from having contributions from regional companies involved with Responses to these comments are provided in 1960 building to give it more depth. In the past, investment and creation of extra jobs have not been Melksham the Melksham section. taken on board by Wiltshire Council where there is controversy over a major planning application. To answer Q2 : No because cannot understand what is being proposed - needs to be clarified with less use of the word strategic! Chapter: 5.11 MELKSHAM COMMUNITY AREA STRATEGY Question: 15 Paragraph: There is a basic misunderstanding of the composition of the Community Area as both Berryfield and Bowerhill, described as "towns" on your map Pg 90, are in fact separate communities from Melksham Town within the rural parish of Melksham Without and with village identities. Both regularly enter for the Best Kept Village Competition. Berryfield has a "Village policy limit". Bowerhill should be identified at least as a large village, if not a Larger Service Centre since it is 2 miles from Melksham and separated from Melksham by green fields. While it is the largest employment area near Melksham, this employment serves the whole of the community area including Bowerhill itself. It has its own level of self-containment with a Residents' Association, a school, comprehensive recreation facilities, newsletter, a shop and numerous village organisations. Berryfield too has its own residents' group, play area, allotments etc. Neither area wishes to be part of the Melksham town parish. Berryfield is characterised by having Grade 1 Agricultural land, is very rural, and has more in common with Whaddon than Melksham. Table 5.18 is also misleading because it divides Shaw and Whitley into two separate villages although traditionally they have grown up together and are linked by sharing a village school, a village shop, a network of footpaths and a playing field. Taken together they are self-contained and offer a wide range of services and facilities. Beanacre also needs to be included as a small village. 9these corrections would then tie in with your opening statement "A number of villages lie close to the town.." Thus Table 5.18 Cross Comment No. Comments Officer Comments Issue Reference By needs to be amended to include: Market Towns: Melksham Local Service Centres Bowerhill OR in Large Village category Large Villages (Bowerhill) Shaw and Whitley Small villages Beanacre Table 5.19 also needs to be amended in the light of the proposed changes above, as it is likely the remainder of housing to be identified (736) may be envisaged for the whole area of Melksham, Berryfield and Bowerhill. This needs to be made clear. For infrastructure, (3) more details needs to be given re the community aspiration to improve Melksham Railway Station and services. For (4) this should include the urgent need for provision and enhancement of cycleways not only in the town area, but to link the rural villages such as Beanacre and Broughton Gifford to Melksham so that people can reach them safely without using a car and have a more sustainable means of transport. For (5) the locally well-known and loved Riverside Walk (Melksham's Millennium project) should be formally recognised as a public footpath and protected as a community asset, for the future. For (6) it appears to be an omission from the Core Strategy that there are no policy statements relating to the restoration/reconstruction of the W&B Canal, given the recent progress with the project and thepossible commencement ofimplementation within the period to 2026. However, there needs to be some assurances given that this very welcome development will not be permitted to have a detrimental effect on existing activities and facilities along its route. Also that it will not beallowed to encourage inappropriate development in the countryside, the loss of higher grade land from agricultural use or the coalescence of communities (e.g. Melksham with Berryfield). COMMENTS ON INDIVIDUAL TOPIC PAPERS PAPER 1 CLIMATE CHANGE My Council is dismayed to note that while nationally and in the south-west there is a 2.1% decrease in the amount of carbon emissions, Wiltshire is up by 3%. Wiltshire contributed to the 2 nd lowest Comments noted. The transporting of waste and level of renewable energy in the south west and made the lowest contribution of renewable subsidies for bus services are beyond the scope Incompatibility heat. In Wiltshire 90% of renewable electricity comes from land-fill gas which is a finite source of the core strategy. However, the council’s between the so we need to find another source to meet climate change targets. Only 0.7% energy comes Energy Change and Opportunity (ECO) Strategy council’s 1960 from solar panels. There is also concern at the apparent incompatibility between Wiltshire 2011-2020 sets out the council’s ambitions for approach to Melksham

Council's approach to various key issues The objectives for greater sustainability do not tally reducing its carbon emissions as an organisation various issues with plans to ship waste around and in and out of the county by road. 9Holland uses canals to and preparing for unavoidable climate change. in relation to great effect here) Subsidies on bus services are also being withdrawn which encourages The ECO strategy covers eight themes for action, sustainability greater private car use. While this paper poses many questions it provides very few answers, including waste and transport. and this is not surprising due to the lack of knowledge on the part of officers and councillors about what is such a specialist subject. The proposed core policy 26 (sustainable construction and low-carbon energy) in the June 2011 consultation document states that “retrofitting measures to improve the energy Retrofitting of There needs to be an additional policy to make existing and older properties more sustainable. performance of existing buildings will be 1960 existing Melksham encouraged” in line with a hierarchy which seeks properties to first reduce energy consumption, then use renewable or low-carbon energy from a local/district source, and then use building- integrated renewable or low-carbon technologies. The proposed core policy on green infrastructure would require the provision of public open space in accordance with the requirements of the Wiltshire Open Space Standards. There are While assent is given to having larger gardens to grow vegetables, this is not borne out by currently four sets of open space standards which recent major planning applications which provide miniscule gardens without any challenge. are in operation in Wiltshire covering the four Allotment 1960 Making more land available for allotments and encouraging Area Board to give grants to help Melksham former district council areas. The standards for provision parish council to provide more allotments as well would help a great deal. the west Wiltshire area include allotments at

1.5sq m per person. Any allotment provision to be provided (or enhancements to existing facilities to be funded) by a developer would be calculated on a site specific basis, taking account of any Cross Comment No. Comments Officer Comments Issue Reference By existing provision in the area. The June 2011 consultation document includes core policy 8 which states that “the development of a low-carbon renewable district energy/heat network in Trowbridge will be encouraged and At Trowbridge we have heard of an interesting project to heat new development from power supported”. station pipes and more such projects are needed if Wiltshire is to catch up with other counties. Wiltshire Council could also become involved in providing more education via leaflets and Comments relating to leaflets and grants are 1960 grants to householders so that they are proactively encouraged to be more sustainable, with a beyond the scope of the core strategy. However, Melksham

yearly award for the most sustainable older/existing property. the council’s Energy Change and Opportunity (ECO) Strategy 2011-2020 sets out the council’s ambitions for reducing its carbon emissions as an organisation and preparing for unavoidable climate change. This covers ‘communicating environmental issues’ as one of eight themes for action.

It is intended that detailed design guidance will be prepared by the Council to assist with the Melksham Without Parish Council notes that you intend to prepare four specialist papers and selection of appropriate technologies which will we would be grateful to be given an opportunity to comment on these Please note there is an cover sustainable construction and low-carbon 1960 Melksham error at Clause 5.2.5 line 2 which should be amended to read: "power stations typically do not energy generation, including appropriate utilise the majority of heat". approaches for historic buildings and buildings within Conservation Areas. There are no detailed plans as to how this document will be prepared at present. TOPIC PAPER 2 HOUSING There is a need to provide sufficient land and achieve the appropriate housing balance to fit in with local communities; to bring back empty properties into use and utilise existing land efficiently and to provide high quality building layouts with densities appropriate to individual settlements. As regards definitions of "affordable housing" my Council has reservations about the Government definition as Clause 3:19 ; "including social rented and Comments are noted and there is some careful intermediate housing provided to households whose needs were not met by the market." We well planned growth being proposed at large feel provision of cheaper housing should be for people who otherwise would not afford to villages such as Whitley. Planning obligations and remain in their home area. To survive, villages such as Whitley need more affordable 1960 site proformas included with the Core strategy will Melksham properties. Without this growth villages will die and this adversely affects local schools as well. attempt to ensure the timely delivery of housing, At Shaw School there is over capacity because people came to it from other areas. Offspring of however this is often subject to complex legal the indigenous population cannot afford to live in the village. The average 25% deposit is agreements. £40,00 - £50,000 and very few young people can afford it. It would be better to provide housing which could be owned on a 25%/75% basis with flexibility to enable young people to buy a further share of a property later on, if they could afford it. The currency is the price of land. If developers had to release more land on to the market, this would slow up the growth in house prices. PAPER 4: SUPPORTING RURAL AREAS The Parish Council very much welcomes the government response to The Taylor review of the Rural Economy in that it recognises and wishes to encourage economic growth in rural areas and support home-based businesses. The The Core Strategy attempts to put rural increased housing supply for Wiltshire should focus on affordable housing which local people regeneration at the heart of policy. Core Policy 32 can afford. Large 4 bed houses encourage commuters to use Wiltshire as their base and work looks to protect community facilities, however 1960 elsewhere. 2.4. Improved opportunities for cycling should include new cycleways to link rural Melksham policies to encourage new facilitates do need to areas to the towns. 2.5. There needs to be pro-active encouragement to re-opening village be included and this will appear in the next draft services such as post offices where the population is more than 1,000 e.g. at Bowerhill, which of the Core Strategy. has a 3,000 = population and yet has recently had its post office closed. Residents now have to travel into town to use the only remaining Post Office in Melksham where there are always queues because it is over subscribed. 2.6. Parish councils should be involved in further efforts Cross Comment No. Comments Officer Comments Issue Reference By to ascertain housing need and have a say in ensuring that new affordable housing first serves the indigenous population. 2.7. More effort is needed to ensure housing design is fully sustainable e g. rules to ensure use of voltaic cells, underground heat pumps etc. 2.8. Farmers need to be actively consulted and involved in any plans for diversification. 2.9. Criteria set for use of buildings in the open countryside should be limited either to agricultural use in its widest sense, to ensure Wiltshire remains a rural community or to affordable housing. Once land is developed it cannot be retrieved for farming again, so care needs to be taken that new policies do not result in entrepreneurial mass housing development to line developers' pockets. It is local young people who need to be encouraged to stay and work in the county through having somewhere affordable to live. 2.14. The Parish council supports the re-use of existing buildings for tourism as long as it does help the local economy and promote local culture 2.17 A survey needs to be done of young people who grew up and were educated in Wiltshire but who, for a variety of reasons were unable to find employment here. More needs to be done to directly help graduates returning from universities to find jobs locally so that there skills can be utilised to benefit the local economy. 2.18 Local Service Agreement All the six ambitions identified by law need to be implemented in liaison with local councils. A statement should be made in this paragraph to that effect. 3.0 The collection of documentation is very helpful. Wiltshire Council needs to ensure that all the local councils understand and are involved with implementing the policies found in these documents. TOPIC PAPER 5 THE NATURAL ENVIRONMENT/BIODIVERSITY Most communities are very concerned about wildlife but this document only pays lip service to them. Planning officers Noted. Protection of rare species will remain a often minimise local concerns to protect flora and fauna in favour of keeping developers happy. priority for all new development. The Biodiversity 1960 Most communities and parish councils do not know about the rare species in their area Melksham Action Plan published by the Council does because they are not kept informed. If local councils in Wiltshire were given a list of protected or include a list of rare species. unusual species they would then be able to take active steps to ensure they were safeguarded. Please can local councils be sent details of rare plans and wildlife in their areas 1960 TOPIC PAPER 6 WATER MANAGEMENT & FLOODING - NOT AVAILABLE Melksham

TOPIC PAPER 7 RETAIL Melksham is described as having a relatively healthy retail centre with a range of building types. However out-of-town stores and supermarkets such as Asda, Aldi and Leekes do affect the town viability. There appears to be only one place in Melksham where more shops could be installed and this is around the large car park behind Avon Place. Please would Wiltshire Council proactively encourage this and include artists' impression drawings to stimulate debate. There is an emphasis on retaining the current shopping area boundaries. Price Waterhouse has recently reported that in the future 25% of shopping units in all high streets could disappear and supermarkets take their place. To prevent this Wiltshire Council needs address the very difficult problem of the high costs of rents. Some are £300 per Policies within the Core strategy do look to week; far too high for small struggling businesses. The Carpet Barn recently shut down due to a prioritise town centre development, and it is rent rise. When Melksham Without Parish Council was looking for a ground-floor unit, a few recognised in the Melksham Community area years ago, there was nothing under £12,000 per annum. This document also makes no mention strategy that development must now focus on the of Wiltshire Council's very unwise decision to take away the free 1 hour parking and impose 1960 town centre. However, a number of issues in the Melksham high car parking charges. This policy has had a devastating effect upon Melksham especially comment refer to things outside to control of when combined with the tardy and frustrating highway works in the main High Street for months planning such as car parking charges. These on end which has driven many businesses to the wall. The town desperately needs positive comments will be passed on to the relevant affirmation that Wiltshire Council is on its side, not working against it. In such circumstances, officer within the council. one cannot blame residents who now choose to go to Sainsburys or Asda where parking is free to get all their commodities. There must be incentive to persuade people to come back to shop in town, such as 2 hours' free parking, or free vouchers for local shopping in wilts. Council newsletters. Many individual small shops are now disappearing and some have been replaced with charity shops. My Council questions the length of time charity shops are allowed to remain at premises, especially if they are selling new goods. It is recommended that there should be a five year licence after which they should be charged full rates. The larger supermarkets; now with very sophisticated marketing techniques are able not only to offer a huge range of products, but a huge range for just same product,. The large Conservation area and Listed Cross Comment No. Comments Officer Comments Issue Reference By Buildings in Melksham can make it difficult to change an area. There is a lack of larger premises for shops such as Wilkinsons. The area around the old carpet shop, which was a cheap 1960s construction in 1960s needs to be pulled down and re-built. We feel that if more flats above shops were let this would encourage more people into the area at night . The town would benefit from a weekend night economy with more shops opening late in the summer. TOPIC PAPER 1O THE HISTORIC AND BUILT ENVIRONMENT. This paper contains plans to ensure new development meets quality and high design standards, to fit in with the existing built and historic environment. The Parish Council feels that it is important too, that social housing meets the same standards. At present when new development t takes place, local The proposed core policy on design and place councils are inundated with complaints which are always passed on but too often fall on deaf shaping would apply to all development ears as far as planners are concerned. The Parish Council is therefore not surprised that 30% 1960 proposals, including those for affordable housing. Melksham of new homes are poorly built and 36% of new homes failed to reach current standards. How The impacts of the policy will be monitored often do we have to tell you!! Take the new development near Snarlton Lane, for example. through the Wiltshire Monitoring Framework. There are 20 criteria to meet for new housing and here as in other places, only 4 of the criteria have been met. Planning Officers need to be more diligent in ensuring that new development does meet the required standards and for this to be achieved they need far more encouragement from local councillors, not just criticism. The Melksham Area Strategy in the June 2011 Priority should be given to ensure new development is built in conjunction with sustainable consultation document states that “It is important transport facilities to ensure residents can walk or cycle into town. There needs to be new areas that any new development in the town has strong of open space within new developments to increase the overall amount of public open space in walking and cycling linkages to the town centre”. Melksham To ensure that standards for new developments are improved, Wiltshire Council The proposed core policy 36 on green should ask for a large deposit bond for the various benefits of the S 106 Agreement which is infrastructure indicates that developers will need only returned in full if standards are fully met; i.e. all 20 criteria. Places such as Stonehenge to make provision for public open spaces in 1960 and Avebury, well-known World and National Heritage sites, are well protected. However it is Melksham accordance with the Wiltshire Open Space the many unlisted buildings which add to the overall historical ambience of a place and these Standards. need to be protected as well. While the words and ideas of the Strategy were good nobody

appears to be taking responsibility for putting them into action. Melksham Without Parish Consideration will be given to adding reference in Council wishes to formally request once again for The Spa to be protected as an historic the Melksham Area Strategy to the need to environment. We have making representations for this to be a Conservation area for many protect the historic setting of the Spa for the pre- years but our views are always ignored. submission draft core strategy. TOPIC PAPER 11 TRANSPORT Much of the content from this Paper appears to come from past Local Transport Plans over the past 10 years. There is an urgent need to reduce long The core strategy seeks to address out- distance out-commuting. In Wiltshire this is 29% of the work force as there are no jobs to go commuting by providing a balance of housing and with all the housing. There is also a need to improve health by reducing car use. In Wiltshire, employment land, offering the opportunity to help Melksham

priority is being given to national goals to increase economic growth, to reduce carbon improve the self-containment of Wiltshire’s emissions and to improve health. The goal considered least important is equality of opportunity. settlements.

Present policies are not deliverable. This paper includes a priority list for road users, and while pedestrians and cyclists had been put near the top with private drivers at the bottom, in practice it is always the other way round. Wiltshire Council never seems to be able to deliver on new cycleways. Many roads are just too dangerous to cycle; e.g. the Bradford Road into the Countrywide Farmers roundabout. Within Melksham, the recent widening of pavements means The policies are considered to be deliverable. The that some HGVs and buses cannot easily use the roads and this then puts more pressure on 1960 impacts of the policies will be monitored through Melksham cyclists. Within new residential estates, some of the roads are too narrow for bus use which the Wiltshire Monitoring Framework. means pedestrians have to walk a long way to get the bus. My Council notes that in future, applicants of larger planning commercial applications would have to produce a public parking management plan which could mean in time supermarkets charging for parking. Yet people who do not use a car are already subsiding car users through taxes. Car users should have to pay for car use. In the future, Wiltshire needs to achieve more sustainable freight transportation, to balance the The proposed core policy 47 (movement of needs of the countryside and the environment. In past years there has been a Freight goods) states that “the council and its partners 1960 Melksham Partnership to draw together interested parties. As this no longer exists, a new Transport will seek to achieve a sustainable freight Partnership is needed which also includes other road users such as cyclists. This Paper states distribution system”. Support for improvements to Cross Comment No. Comments Officer Comments Issue Reference By too that overnight parking facilities would be provided where a need for them could be rail facilities is noted. demonstrated. However when my Council tried to raise the need for replacement lorry parking facilities for Melksham, it was told that these problems were a matter for the Police. The Parish Council is very pleased to note that the Transport Paper gives priority to improving rail facilities at Corsham, Melksham and Wootton Bassett. There is to be a new military site at Corsham. In the past Wiltshire Council has missed out on linking in to the Oxford to Bristol rail service which had now been discontinued. This Paper concludes with Wiltshire Council putting forward two freight options for the future:- a) to develop and improve sustainable freight facilities. b) to maintain the status quo My Council feels that the status quo is now no longer fit for purpose and they propose that a fresh approach be taken. Stobbarts for example are using a rail-freight system to make deliveries to local pubs. Wiltshire Council needs to utilise rail services and canals in the deliver of freight. TOPIC PAPER 13 - GREEN INFRASTRUCTURE This Paper makes a number of good points. The key themes were "multi-functionality" and "connectivity." There is an emphasis on encouraging healthy lifestyles and improving the quality of community life through careful 1960 design which made natural features easily accessible. We are pleased to note that Wiltshire Support noted. Melksham

Council is recommending that existing wildlife corridors be protected and enhanced. This policy needs to be more rigorously applied to domestic planning applications where hedges etc are often removed and replaced by panels TOPIC PAPER 14 - SITE SELECTION PROCESS My Council notes that strategic sites for future development are Chippenham, Trowbridge and Salisbury and elsewhere there are non- strategic sites such as Melksham where 400 extra dwellings are needed. The Parish Council STRONGLY OBJECTS to any development taking place between Melksham and Bowerhill or to the rear of The Spa. It is unclear whether sites are still being promoted. No assessment appears to have been done on other alternative sites. While some development may take place to facilitate the construction of the Wilts. and Berks Canal I t is important that the Grade 1 Agricultural Land at Berryfield is not lost. Further assessment is needed for these sites. Earlier in the consultation process Melksham Without Parish Council suggested that land off Sandridge Common, behind Burniston Park should be developed. Development on the other side of the A3102 is an obvious logical progression from the east of Melksham and could help finance A response to this comment is provided in the 1960 Melksham more of a future Melksham Eastern Bypass. The number of planned housing units for Melksham section. Melksham appears relatively low since it is not a Strategic site. There is a total of 1930 required, 309 of which are to be completed in 2011. There are already 835 permitted sites, which leaves 736 to find. Of these 270 are scheduled to go on the old George Ward site, leaving just over 400 to be built in the next 15 years. Please inform what areas are intended for this development. My Council STRONGLY OBJECTS to any development which will further increase traffic on A350 through Beanacre. This road is already well over its design capacity and we are concerned that if the BANES Local Authority succeeds in their bid to get HGV traffic off A36, this could all end up being diverted along A350. Please take this up on behalf of the parish Council and the Beanacre community. No more traffic along A350 through Beanacre!!. Develop the rail links instead. TOPIC PAPER 16 - BUILDING RESILIENT COMMUNITIES. My Council notes that Wiltshire still has pockets of rural deprivation. We are very concerned to see a Post Office re-opened at Bowerhill. Too many shops have been closed and we note that the country 40 pubs are closing every week. Public houses are important as centres of social activity. So are churches which The June 2011 consultation document includes appear to have been completely overlooked by your Paper! Many of these offer vital community core policy 32 which seeks to protect existing facilities such as Sunday services; so important for building community spiritual life, Mums and community services and facilities. Consideration 1960 Toddler Groups, Youth Clubs, Coffee mornings, Craft sessions and help for elderly residents. will be given to adding a specific policy on Melksham

My Council supports the principles of retaining wildlife habitats and of involving communities in ‘supporting rural life’ for the pre-submission draft dealing with litter and fly-tipping. As regards consideration of the following three issues;- a) core strategy. Bus pricing and timetabling are Transport - While rural communities do need reliable and affordable public transport, most are beyond the scope of the core strategy. having to accept the use of cars as essential to survival. b) The need for basic community infra- structure. While your Paper recognises that communities need facilities to survive, there does not appear to be a methodology for achieving this. c) The need for leisure and recreational Cross Comment No. Comments Officer Comments Issue Reference By facilities . You recognise that better youth facilities are needed but again, there are no suggestions as to how this would be done. One way would be to make grants available for training youth workers to operate in the villages. My Council also has concerns that some bus fares are quite high. The cost of a trip into Devizes from Bowerhill, for example, is £6.80. High fares encourage more use of private cars. It is felt that the present pricing structure and practise of buses following on another along the same routes does not help communities.

I am worried about the level of housing growth with its implication of no longer keeping to the Comments noted. The strategy includes specific sequential test and the increased traffic it will generate. It seems to me to be important to 1979 policies which seek to promote sustainable forms Question 2 increase jobs before any new houses are built and very necessary in this respect to try to help of transport. small businesses.

We are long term residents of Wiltshire (nearly thirty years), and wish to register our strong objection to the proposal to build 37,000 houses in our county and develop up to 182 hectares Objection noted. The strategy includes specific of "employment land" between 2006 and 2026. The damage to the rural character of the policies which seek to protect the natural 1980 county, loss of natural habitat for animals, birds and insects and increase in traffic on already Question 2 environment and promote sustainable forms of full roads, are unacceptable. Wiltshire should take the opportunity to scale back the massive transport. over-development proposed by the last government and determine to do as little further damage to our environment as possible.

Petitt Brothers Contracting Ltd is conscious that the Core Strategy will need to have regard to, and be able to adapt to, new/changed elements of policy in the emerging NPPF, which is currently a material consideration and will probably be in force by the time the Core Strategy is The Council will ensure that the Core Strategy is 1984 examined and adopted. In particular: The 5 year + 20% deliverable land supply requirement; compliant with the NPPF and the new Localism NPPF Q22 The presumption in favour of sustainable development and the circumstances in which it will Bill as and when these documents develop. apply; The emphasis on economic growth; The emphasis on viability/deliverability of developments and not placing onerous S.106 requirements.

I am writing to express my views generally on Wiltshire Council's Core Strategy draft statement. In particular I write to express my opposition to the two central tenets of the core strategy, Noted - National policy, particularly in the form of namely the supposedly scaled-down provision for 37,000 new houses and the 175-182 PPS3 & PPS4, states that through the Core hectares of new employment land. No overwhelming case for such a small reduction in new Strategy the council should promote greater housing is made and the downside damage to the Wiltshire countryside arising through levels of development at settlements with the adoption of these substantial targets is both tangible and predictable. As I write, I fail to see any facilities and infrastructure to support that need for new employment land at all given the scale of the problems we are now witnessing development and provide the best opportunity to globally, from which it will take many years to recover. Moreover, the downside effects of the offer jobs and homes in the most sustainable Greenfield development are minimised in the draft spacial strategy. This suggests to me that manner. The designation of the principal the policy statement is more an exercise in salesmanship than anything else. From information settlements allows the best opportunity for 1998 provided to me by Wiltshire C.P.R.E, I understand that many counties in England have now Wiltshire to fulfil its requirement for jobs and Question 2 substantially reduced their housing development plans, in some cases by as much as 50%. Yet homes within environmental limits. Topic paper the figure for Wiltshire, of 37,000 homes and the acreage for new employment land, indicates a 17 paper sets out the progress made in reduction of only 12%. As a largely rural and agricultural part of England, I believe our county determining an appropriate requirement and should do its utmost to retain its essentially rural nature, by minimising the number of new distribution of housing for Wiltshire from 2006 to houses built in any one planning period and to maintain a hardline policy in respect of 2026 to inform the draft Wiltshire Core Strategy. preserving all Greenfield land from development. As such I would expect to see a far more This process considers the strategic objectives for substantial reduction in both the number of new homes projected for the plan. New industrial the county as well as taking into account local development should similarly take place on brownfield sites and allowance should also be factors and aspirations for growth identified made for the increasing numbers of people who opt to work from home. The scale of the through community consultation. development forseen in the plan is unprecedented for a fourteen year cycle, yet none of the Cross Comment No. Comments Officer Comments Issue Reference By potential downside effects are properly analysed and measured, at least in an honestly described way as I would want to see. It all comes across as gloss and salesmanship. Development of Greenfield land - which the core strategy is ultimately predicated upon - has noticeably damaging effects with regard to the continued erosion of the countryside. Why is this considered acceptable? Why not honestly spell out the ill effects of such large scale proposed development. The large urban extensions and out-of-town industrial estates developed largely on Greenfield land, envisaged for places like Salisbury, will inevitably require accompanying infrastructure development of roads and such like, placing ever increasing demands on land, energy production and consumption. Even the smaller towns like Marlborough do not escape the transformation of Greenfield land to housing development. I suggest this is hardly an expression of sustainable development. Overall, the core strategy is a plan that will lead to further erosion of the natural countryside environment and direct loss of agricultural land. To me this is unacceptable. It will lead to a further decline in our town centres and the growth of more characterless car-based suburbia of the type which can now be considered to be a blight; where one could be literally anywhere in England and not really get a sense of where one is. There will be increased traffic, traffic congestion, urban noise and pollution, including light pollution, in both towns and villages. The presumption of continued growth worries me. How can we reconcile this unprecedented scale of growth as concomitently meeting the obverse objectives of protecting the environment and sustainability? I don't believe we can, certainly not on the numbers projected and I do not, therefore, support adoption of the draft plan for these reasons.

Paragraph 5.0.13 states: " Remainder to be identified: this is the number of new homes for which a specific location has not yet been identified. These could come forward as windfall sites within existing urban areas and/or as Greenfield sites on the edge of settlements that are identified through community led Neighbourhood Plans or a site allocations development plan document prepared by the local planning authority with community input ." There is a The Council will ensure that the Core Strategy is 2014 significant level of residential requirement still to be identified. This approach is not thought to compliant with the NPPF and the new Localism NPPF Q22 be appropriate or in compliance with the policy contained within the draft National Planning Bill as and when these documents develop. Framework. Any proposals for housing development must be assessed having full regard to the possible impact of existing and future military training and operations upon potential new residents. Military operations and training must be safeguarded as essential to defence purposes.

Paragraph 6.8.3 states: " Planning developments in locations that are, or can be made Locations can be made more accessible by the accessible means that communities can access their needs (e.g. shops, schools and provision of local services, sufficient for the employment) easily and without always needing a car. Providing good accessibility can also development, and by the provision of suitable change people's travel behaviour towards more sustainable transport alternatives such as public transport. However, this requires that the walking, cycling and public transport ." This statement accepts that sites can be made more services would have to cater for the development accessible than they are at present. However, this principle does not seem to be taken into in its entirety or that the public transport solution account in proposed Policy 24. PPS 3 states: " At the local level, Local Development would negate additional car-borne travel. In this Documents should include a local previously developed land target and trajectory (having context, those locations that could realistically be 2017 SO8 regard to the national and regionalpreviously-developed land target in the Regional Spatial made more accessible are those which are Strategy) and strategies for bringing previously-developed land into housing use. In already very well related to the existing urban developing their previously-developed land strategies, Local Planning Authorities should form. Core Policy 24 seeks to support the consider a range of incentives or interventions that could help to ensure that previously redevelopment of military establishments, developed land is developed in line with the trajectory/ies. This should include: - Encouraging particularly where these are previously innovative housing schemes that make effective use of public sector previously-developed land developed, providing that suitable mitigation can ." Proposed Policy 24 specifically discourages the effective use of public sector previously be provided such that the development will be developed land and therefore is in direct contravention of adopted national policy. sustainable. Cross Comment No. Comments Officer Comments Issue Reference By

Tanya Owen Bines is conscious that the Core Strategy will need to have regard to, and be able to adapt to, new/changed elements of policy in the emerging NPPF, which is currently a material consideration and will probably be in force by the time the Core Strategy is examined The Council will ensure that the Core Strategy is and adopted. In particular: The 5 year + 20% deliverable land supply requirement; The 2039 compliant with the NPPF and the new Localism NPPF Q22 presumption in favour of sustainable development and the circumstances in which it will apply; Bill as and when these documents develop. A preference of reuse of existing buildings and previously developed land for residential and other uses; The emphasis on economic growth; The emphasis on viability/deliverability of developments and not placing onerous S.106 requirements.

The 8 week consultation period in the middle of the main holiday period is not inclusive and wholly inadequate. It is the most popular time of year for people taking holiday leave, families involved in activities associated with the end of the school year, local community fundraising events such as fetes and festivals, and staff of local businesses taking annual leave, resulting in local residents, businesses and community groups and other key stakeholders being unable to respond to a document of this size, as they would wish. The Consultation Period should be extended into the Autumn. There are concerns that there are many local residents who do not Comments noted. The overall Core Strategy know about the draft Core Strategy and the current consultation exercise. More direct timetable meant that it was necessary to hold the household consultation should have been carried out in the form of leaflets to individual consultation during the summer. The consultation properties as well as regular press notices. The current consultation may thus be considered to began before the school holidays on June 13th Consultation 2043 be unsound. The draft National Planning Policy Framework has now been published. The Core and ended on 8th August. All the events were Q22 process Strategy will need to comply with this framework. The contribution of farming and the rural held before the school holidays and so it was felt economy to Wilshire and surrounding areas should be included in the Core Strategy? The that this gave the opportunity for as many people contribution of tourism to Wiltshire and the surrounding area should be included in the Core as possible to comment before they went on Strategy? 40% affordable housing provision is too high and not in accordance with the draft holiday. NPPF which allows Councils to set their own thresholds. It is welcomed that all consultation responses received will be available for public inspection. It is hoped that the Council would not designate land and sites for development without the majority consensus of the local community. The draft NPPF supports the implementation of neighbourhood planning which is being introduced in the Localism Bill. This allows local communities to define the type of development that reflects their vision of what their areas should look like. If it would assist, the Badminton Estate would welcome the opportunity to provide an accompanied tour of the Estate's areas covered by the Wiltshire Core Strategy - and to demonstrate the range of rural economy and community issues that will no doubt apply to much of the Wiltshire area. As a land owner covering significant farming, forestry and rural settlement areas within this part of Wiltshire (and adjoining land within South Gloucestershire), it may well assist the County to have such a visit as part of the county's ongoing review for rural areas. If it would help to have any further information or discussion at this stage, then please do not hesitate to contact either Simon Dring at the Badminton Estate office or myself. At paragraph 5.1.5 of the Core Strategy bullet points 8 and 9 refer to areas around Chippenham and the Comments noted. Work is continuing to develop outlying settlements which are identified as larger villages - although noting constraints that will the Settlement Strategy. Agree we will consider apply to the type and level of future development. Although it is understood that the emphasis the issues of opportunities for further Settlement 2056 Chippenham for new development and regeneration will be on Chippenham and other major towns close by - development in villages and the rural areas Strategy which may include Calne and Malmesbury, in order to address the occurrence of commuting including land owned by Badminton Estate from rural areas and the almost inevitable reliance on private car transport - it is considered further. important that where possible and suitable, both employment opportunities and some appropriate new housing should be considered in rural areas - especially where either individual villages or close knit groups of rural villages are able to provide a reasonable level of rural community services and infrastructure - including employment. It is also noted that in response to Question 5 for the Chippenham Community Area, unlike Question 13 for the Malmesbury Community Area, the question does not raise the opportunity for any changes to be suggested for the Spatial Strategy outside the proposed future growth in Chippenham. Notwithstanding the requirement to be in accordance with the settlement strategy set out in Cross Comment No. Comments Officer Comments Issue Reference By Core Policy 1, our response to Question 5 includes the suggestion for additional consideration within rural areas and as also covered by responses to core policies set out within Chapter 6 of the Consultation document and the delivery of strategic objectives.

National Grid has appointed AMEC (formerly Entec) to review and respond to development plan consultations on its behalf. We are instructed by our client to submit the following representation with regards to the current consultation on the above document. Overview - National Grid National Grid is a leading international energy infrastructure business. In the UK National Grid's business includes electricity and gas transmission networks and gas distribution networks as described below. Electricity Transmission National Grid, as the holder of a licence to transmit electricity under the Electricity Act 1989, has a statutory duty to develop and maintain an efficient, co-ordinated and economical transmission system of electricity and to facilitate competition in the supply and generation of electricity. National Grid operates the national electricity transmission network across Great Britain and owns and maintains the network in England and Wales, providing electricity supplies from generating stations to local distribution companies. We do not distribute electricity to individual premises ourselves, but our role in the wholesale market is key to ensuring a reliable and quality supply to all. National Grid's high voltage electricity system, which operates at 400,000 and 275,000 volts, is made up of approximately 22,000 pylons with an overhead line route length of 4,500 miles, 420 miles of underground cable and 337 substations. Separate regional companies own and operate the electricity distribution networks that comprise overhead lines and cables at 132,000 volts and below. It is the role of these local distribution companies to distribute electricity to homes and businesses. To facilitate competition in the supply and generation of electricity, National Grid 2069 Noted Q22 must offer a connection to any proposed generator, major industry or distribution network operator who wishes to generate electricity or requires a high voltage electricity supply. Often proposals for new electricity projects involve transmission reinforcements remote from the generating site, such as new overhead lines or new development at substations. If there are significant demand increases across a local distribution electricity network area then the local network distribution operator may seek reinforcements at an existing substation or a new grid supply point. In addition National Grid may undertake development works at its existing substations to meet changing patterns of generation and supply. Gas Transmission National Grid owns and operates the high pressure gas transmission system in England, Scotland and Wales that consists of approximately 4,300 miles of pipelines and 26 compressor stations connecting to 8 distribution networks. National Grid has a duty to develop and maintain an efficient co-ordinated and economical transmission system for the conveyance of gas and respond to requests for new gas supplies in certain circumstances. New gas transmission infrastructure developments (pipelines and associated installations) are periodically required to meet increases in demand and changes in patterns of supply. Developments to our network are as a result of specific connection requests e.g. power stations, and requests for additional capacity on our network from gas shippers. Generally network developments to provide supplies to the local gas distribution network are as a result of overall demand growth in a region rather than site specific developments. Gas Distribution National Grid also owns and Cross Comment No. Comments Officer Comments Issue Reference By operates approximately 82,000 miles of lower-pressure distribution gas mains in the north west of England, the west Midlands, east of England and north London - almost half of Britain's gas distribution network, delivering gas to around 11 million homes, offices and factories. National Grid does not supply gas, but provides the networks through which it flows. Reinforcements and developments of our local distribution network generally are as a result of overall demand growth in a region rather than site specific developments. A competitive market operates for the connection of new developments. National Grid and Local Development Plan Documents The Energy White Paper makes clear that UK energy systems will undergo a significant change over the next 20 years. To meet the goals of the white paper it will be necessary to revise and update much of the UK's energy infrastructure during this period. There will be a requirement for: an expansion of national infrastructure (e.g. overhead power lines, underground cables, extending substations, new gas pipelines and associated installations); and new forms of infrastructure (e.g. smaller scale distributed generation, gas storage sites). Our gas and electricity infrastructure is sited across the country and many stakeholders and communities have an interest in our activities. We believe our long-term success is based on having a constructive and sustainable relationship with our stakeholders. Our transmission pipelines and overhead lines were originally routed in consultation with local planning authorities and designed to avoid major development areas but since installation much development may have taken place near our routes. We therefore wish to be involved in the preparation, alteration and review of Development Plan Documents (DPDs) which may affect our assets including policies and plans relating to the following issues: any policies relating to overhead transmission lines, underground cables or gas pipeline installations; site specific allocations/land use policies affecting sites crossed by overhead lines, underground cables or gas transmission pipelines; land use policies/development proposed adjacent to existing high voltage electricity substation sites and gas above ground installations; any policies relating to the diverting or undergrounding of overhead transmission lines; other policies relating to infrastructure or utility provision; policies relating to development in the countryside; landscape policies; and waste and mineral plans. In addition, we also want to be consulted by developers and local authorities on planning applications, which may affect our assets and are happy to provide pre-application advice. Our aim in this is to ensure that the safe and secure transportation of electricity and gas is not compromised. General Comments SWEP would like the following points to be noted and addressed - Considering South Wiltshire has already reviewed and approved the South Wiltshire Core Strategy Document (SWCS) in February this year the current document adds very little to what has already been discussed and agreed. However, we would like to reinforce some general points below in addition to the more specific points relevant to the Tidworth and Ludgershall area included at the end. Issues Raised The ‘ Doughnut Ring' Effect - most significant and important the issue of protecting town centres where all the future growth seems to be centred as a ring around a town leaving a centre with very little to support its sustainability. Town Centre development is seen as paramount to future sustainable communities. The regeneration of Noted. Given the strategic nature of the document Town Centres is not captured in enough detail. There should be targets for regeneration, not specific town centre policies are only included for just housing and employment. There is a definite need to identify the strengths and the principle settlements. Nevertheless there is a Number of 2072 weaknesses of towns and development briefs should be in place, each specifying town Q22 clear commitment in the document to address Issues requirements and aspirations. These development briefs would help promote appropriate these concerns in subsequent Neighbourhood development. Transport structure - very important, links to other areas; there needs to be more Plans. Comments on rural business development connectivity between the road, rail and bus system. Potential development of the Trans Wilts Railway (TWR) link, Salisbury to Swindon, must include careful consideration of all proposed developments near to a railway station that involves the use of car parking, bus connectivity, distance/transport to the town centre, cycle storage, jobs from office accommodation, hotel capacity, town centre facilities and meet the need to feed local business and housing developments. Unemployment Areas - hot spots of unemployment need to be identified; build employment on strengths not weaknesses. Low skill development should be encouraged close to housing. Business clustering, a need to develop future technologies and high volume employment all deemed important to create jobs. Rural Hubs - out of town development, reuse Cross Comment No. Comments Officer Comments Issue Reference By of redundant farm buildings seen as important possible links to development of Hi Tech employment. Encourage rural businesses and more local jobs. MoD - more liaisons over disposal of assets and development within the strategy. Tourism is a sector that is not recognised in sufficient detail. There are concerns that not all land owners agree with a proposed land use, or have been engaged by relevant planners or consultants. Recommendations The consultation document needs to: Strengthen the commitment to securing employment (in particular professional, high skilled/creative employment) in town centres. Protect and safeguard existing employment use buildings and sites for continued employment use. Promote the establishment of and provide support for employment clustering. Core policy 46 - this is ‘unsupportable' and should be reshaped or removed. As it stands it is counterproductive.

Please find following comments on the above strategy from the Cotswold Canals Partnership. The Partnership is a consortium of 18 organisations that has stood behind the Cotswold Canal Restoration for the last ten years. Together the members represent a cross section of interests from District Councils through to national and local charities. Together we are working to restore the Thames & Severn Canal from Brimscombe Port in Stroud through to Lechlade. This cuts across the Malmesbury and the Wootton Bassett and Cricklade community areas. Our main comment is that there are no clear policies in support of the Thames & Severn canal or indeed This issue will be considered for the pre- the Wilts & Berks canal in the strategy. This is a significant omission that ignores the positive submission draft core strategy. Consideration will impact that the restoration of both these canals will have in economic terms as well as the 2074 be given to adding a specific policy to protect the Canals. SO5 beneficial environmental and social outputs that the restorations will deliver. The economic historic alignments of the Wilts and Berks and benefits of restored canals are well documented; the Kennet & Avon canal for example Thames and Severn canals. continues to monitor its delivery against the original predictions and these results are publically available. The Ecotec report completed at the start of the Cotswold Canal Restoration predicts that the completed canal will deliver an additional 215,000 visitor days bringing £531,000 in additional visitor spend each year. It will result in up to £94,000 value in health benefits, 600 new permanent jobs and will facilitate 124 people to gain skills development. It is vital that the canals are included in the strategy, both to safeguard the line of the canals and to ensure that the restoration is reflected in town and parish plans as appropriate. Many thanks Thank you for providing the AONB with the opportunity to comment on this significant document. I note that it seeks to be the core policy document through to 2026 and is, therefore, of particular significance not just for the present time but for a considerable period into the future. The Cranborne Chase and West Wiltshire Downs AONB has been established under the 1949 National Parks and Access to the Countryside Act to conserve and enhance the outstanding natural beauty of this area which straddles three County, one Unitary and five District councils. It is clear from the Act, subsequent government sponsored reports, and the Countryside and Rights of Way Act 2000 that natural beauty includes wildlife, scientific, and Noted. The importance of the AONB's will be cultural heritage. It is also recognised that in relation to their landscape characteristics and highlighted individually in the community area 2079 quality, National Parks and Areas of Outstanding Natural Beauty are equally important aspects Chapter 1. Q22 sections. The landscape policy will be considered of the nation's heritage and environmental capital. The AONB Management Plan (2009 - 2014) further to ensure it is robust. has been approved by the Secretary of State and was adopted by your Council early in 2009. 44% of Wiltshire is nationally designated by the Secretary of State as Areas of Outstanding Natural Beauty. In addition to 61% of this AONB being within Wiltshire (and hosted by Wiltshire Council) some 38% of North Wessex Downs and 6% of Cotswolds AONBs are also within Wiltshire. Along with other AONBs, the Cranborne Chase and West Wiltshire Downs AONB is very aware that AONBs are nationally important landscapes, designated by the Secretary of State, and statutorily required to have quinquennially updated management plans. There is, therefore, a very strong indication that there should be relevant and robust LDF policies to aid Cross Comment No. Comments Officer Comments Issue Reference By and facilitate the purposes of AONB designation, ‘conserving and enhancing natural beauty', and that this is a duty that should not be taken lightly. Indeed the CROW Act 2000 puts a duty on all public bodies and all those in public office to have regard to the purposes on AONB designation in all decisions relating to AONBs. The Core Strategy could, therefore, fail to comply with that duty if it does not have a strong and explicit series of references to AONB matters and associated policies. I note that community areas included in the South Wiltshire Core Strategy are not currently incorporated in the Wiltshire Core Strategy. It is not clear how the over-arching policies of the two core strategies will interrelate; a matter of some significance for this AONB where a considerable area of the AONB falls within the South Wiltshire area. Clearly there are positive supporting statements and useful policies within the document, however I shall concentrate the response from this AONB on the matters that impact on AONBs generally, and this AONB in particular. That said, there do seem to be a number of opportunities that have been missed, particularly in the Introduction and supporting text to provide information and discussions relevant to the various layers of Aims, Objectives, and Policies. Introduction The opportunity, in paragraph 1.4, to focus on quality of life rather than standard of living, has been missed and it is recommended that the document refocuses on quality of life and quality of the environment issues. In that context it is somewhat disappointing to see that paragraph 1.7 omits quality of environment from over-arching priorities. The Vision seems to be somewhat short in its focus in that paragraph 1.9 seems to be very heavily coloured by the current national economic situation, rather than taking a more positive and longer term view to 2026. Nevertheless the focus on local jobs is appreciated by the AONB. However we are concerned that this does not come through clearly in other parts of the document. Furthermore the proposed government changes to the planning system may, in the case of AONBs in particular, militate against the retention of employment sites and buildings at the expense of their conversion to residential uses and the associated outward travel, and travel congestion, to jobs elsewhere. Although it is noted in paragraph 1.11 that the AONB Management Plans have been consulted for the Core Strategy there is no explanation or guidance on the way that AONB Management Plans should be considered, with their national weight, in relation to locally prepared Neighbourhood Plans. Looking at Map 1.1 it is clear that the majority of the community areas include, or are wholly within, Areas of Outstanding Natural Beauty. The AONB, therefore, recommends that there should be very clear guidance, which is not currently obvious, as to how those parts of the community areas will be handled in policy terms differently from areas of countryside that are not of national importance. From the experience of this AONB I should also comment that the part of the Amesbury Community Area that is within the Wylye Valley between Fisherton de la Mere and Great Wishford has greater landscape and environmental similarities to the Wilton area, and is more closely associated to it, than the rest of the Amesbury area. Cross Comment No. Comments Officer Comments Issue Reference By The opportunity to provide a realistic and meaningful spatial portrait has been missed. The AONB would strongly advise that key aspects of the topography, geology and geo- morphological structure should be described to inform and aid understanding of the planning policies. The AONB is also concerned that there seem to be inconsistencies between the classification of transport routes as shown on maps 2.1 and 4.1 and the key diagram found in around the Waste Sites Allocations Consultation document. The key diagram (4.1) of the Core Strategy shows the A350 as a strategic transport route whereas the key diagram in the Waste Sites Allocations Consultation document shows the A350 north of the A303 as a strategic route but not a strategic one south of that point. Clearly the AONB has been fairly relaxed about the A350 as not being identified as a strategic route but we would be concerned if policy The Wiltshire Local Transport Plan identifies the documents start to indicate it as a strategic route with all of the implications of heavy vehicles, A350 south of the A303 as a Principal Route. This and increased numbers encroaching upon, and taking short cuts through, the AONB. is the evidence that has been used in the Furthermore, the transportation study for North and North East Dorset recently carried out by development of the Core Strategy. Dorset County Council indicates that the A350 is not a strategic route and the AONB would greatly appreciate explicit clarification of the situation. The AONB recognises the cross border The intended abolition of the RSS, as well as the relationships identified in paragraphs 2.7 and 2.8 as we also experience a high level of outward intended NPPF and removal of existing Planning commuting for jobs. We would, subject to realistic safeguards relating to conserving and Policy Statements have been carefully considered enhancing landscape, endorse the sentiments in those two paragraphs. The six Key in the development of the Core Strategy. It will be 2080 Chapter 2. Q22 Challenges set out on page 16 do not mention the key challenge that has bedevilled planning ensured that sufficient policies are included to for the last few years, and appears to be about to do so for the coming few years, which is the address any policy gaps at the regional and continuing change by central government to the principles, as well as the fine detail, of the national level. However, it is imperative that established planning systems. There is, furthermore, the prospect of a huge policy vacuum Wiltshire progresses the Core Strategy in order to when the Regional Spatial Strategy is, as government has declared, abolished. The current maintain the plan led system. This will be Wiltshire Core Strategy appears to rely to a very considerable extent on the policies of the RSS enhanced by the progression of neighbourhood being in existence. It is particularly worrying from the environmental point of view that the widely plans, ensuring that localities, in liaison with supported environmental policies of the RSS will no longer exist and the policies within the partners can ensure that appropriate Core Strategy do not appear to be sufficiently specific, robust, or detailed to prevent a policy development occurs at the right time and location. vacuum. This is of great concern as the Core Strategy is planned to be the main policy document right through until 2026. It may not, therefore, surprise you to hear that the Core Strategy document as currently drafted appears to be a mixture of policies similar to those found in the days of Structure Plans that rely on Neighbourhood Plans to flesh things out, and policies from Local Plans that assume the existence of higher level, regional, strategies. However, it looks very likely that those higher level, regional, policies will soon cease to exist. The AONB strongly recommends that the key challenges be reinforced by the insertion of reference to a challenge to conserve and enhance the natural beauty of nationally important AONBs that constitute a substantial proportion of the County. The duty to conserve and enhance nationally important Areas of Outstanding Natural Beauty is considerably more than the provision of Green Infrastructure. The spatial vision should, the AONB recommends, be amended to include specific reference to safeguarding, conserving, and enhancing the AONBs. It may be appropriate to mention within the Core Strategy that the CROW Act 2000 and its subsequent arrangements mean that the nationally important and nationally designated landscapes of AONBs are locally managed, with 75% of the resources for that management provided by central government sources. Therefore, in addition to having Noted, agree. Specific policies are being duties for these nationally important landscapes the local communities are provided with funds produced that will make specific reference to the to ensure that local knowledge and skills contribute to the local management of these nationally 2081 AONB. This section refers to objectives and Chapter 3. Q22 special areas. The relationship between the six Key Challenges and the ten Strategic outcomes being sought. Controls should properly Objectives is not obvious and could be much more clearly structured. Indeed, some of these be set out within the aforementioned policy. strategic objectives appear either to limit the Objective or to include separate issues within a single Objective. We would recommend that Objective 5 be expanded to include not just the natural environment but also heritage and landscape. The Strategic Objective 6 could, with benefit, be separated into an objective to promote high quality design and a separate objective to safeguard the historic environment and encourage beneficial uses of heritage structures. The Strategic Objective 9 seems a little confused in that the provision of infrastructure to support communities seems to be a pre-requisite for the existence of those communities. The wording Cross Comment No. Comments Officer Comments Issue Reference By of Strategic Objective 10 seems to be missing a key word; I therefore recommend inserting ‘maximise' between ‘and' and ‘effective water management'. The nature of AONBs means that populations are not necessarily able to access readily the services that are key features of larger settlements. The AONB would, therefore, strongly suggest that in paragraph 3.4 ‘High quality education services' should be supplemented by the addition ‘of work place training'. Furthermore we are aware that Ministry of Defence land includes extensive holdings and that the simple statement ‘brought within the overall pattern of development' could be both misunderstood and confusing. The larger training areas constitute significant areas of landscape and therefore development might not be appropriate on many MOD locations that might be declared redundant. Without the insertion of caveats relating to the conservation and protection of natural beauty the AONB is very concerned that ‘green jobs', along with some of the outcomes within paragraph 3.5 relating to climate change, could lead to inappropriate developments and activities that generate additional travel. In paragraph 3.6 it seems rather strange that there is specific reference to ‘Western Wiltshire Green Belt' and no reference to the AONBs. Whilst the Strategic Objective is laudable we strongly recommend that this is presented in the context of the national significance of the AONBs. As I have already indicated, the AONBs are particularly concerned about the loss of community facilities within the villages of our AONB and we would, therefore, wish to see achievable ways of retaining these facilities. Moving to paragraph 3.8 it is regrettable that there is no mention of natural beauty and the AONBs whatsoever. There also seems to be a limitation of Green Infrastructure to sites that are publicly accessible and with wildlife value, whereas the original concept promoted by government included a much more holistic, landscape based, concept. Such a concept would, of course, be of considerable relevance to a rural county such as Wiltshire, and the AONB recommends that a more holistic concept of Green Infrastructure is adopted. I question whether, in key outcomes, agricultural soil quality can be improved through planning policies and planning actions. It also appears as though another key word has been omitted in connection with water abstraction and that the key outcome should read ‘the adverse environmental effects of water abstraction will have been reduced'. Regarding high quality design and the historic environment (which, as I have already mentioned, could be separated into two objectives) there seems to be an especially hopeful use of words in the third bullet point. There ‘exceptional' could, as seems to have been intended, mean high quality, whereas it could be exceptionally bad! Similarly in paragraph 3.10, first sentence, the reference to ‘convenient locations throughout Wiltshire' could be misinterpreted as providing a clear steer that major supermarkets would be welcomed everywhere. Strategic Objective 8, paragraph 3.11, seem to have inbuilt conflicts in relation to improving the opportunities to use public transport when the major thrust of the Core Strategy seems to be seeking to discourage commuting. Nevertheless, from the point of view of this AONB, we would like to see the opportunity to use public transport being enhanced and that the railways that already cross the AONB should be more readily accessible to residents and visitors alike. We are acutely aware that one of the railways, the Salisbury to Warminster line, does not stop within the AONB and consequently brings no benefit to the AONB. Cross Comment No. Comments Officer Comments Issue Reference By

Chapter 5 Many of the community areas associated with this AONB are within South Wiltshire. Nevertheless there is still some confusion in the AONB, and the AONB Team does get asked questions about this topic, regarding the allocated numbers of houses and the extent to which the communities of the AONB might be expected to accommodate some elements of this housing. The AONB suggests this needs further clarification. Although the Salisbury Community Area is outside of the AONB it is sufficiently close to be of significant influence, Relationship 2086 See 1456 Q22 particularly in terms of jobs, shopping, and mains services. Mere, Southern Wiltshire, Tisbury, with SWCS and Wilton community areas are within or include significant parts of the AONB and are in the South Wilts Strategy Document. Warminster is the single community area that includes the AONB and is within the current document. Nevertheless the AONB is concerned that the wording of the over-arching policies will relate to all of the community areas and hence the relationship of those polices to the over-arching policies within the South Wiltshire Document.

Core Policy 33 Biodiversity and geodiversity I have already mentioned that this seems to be a rather narrow policy and it should embrace wider landscape and heritage aspects and not focus entirely on wildlife matters. Indeed, by focusing entirely on wildlife matters the Core Strategy could be unbalanced. It also seems that this policy has been prepared in anticipation that regional policy will remain and as that is unlikely it seems crucial that those policies that relate to sites of national and regional significance in the RSS should be included. As it reads at the moment, with the emphasis at the beginning of the policy on local sites, the strategy could end up with having policies that are more demanding for local sites than for national or statutory ones. In relation to the third sentence of paragraph 6.5.1 I recommend rewording it as follows This policy relates to biodiversity and ‘It is the intention that the proposals put forward in this strategy will not, either alone or in geodiversity, while landscape and heritage are combination, have a significant impact on the integrity of landscape, heritage, and wildlife dealt with in the subsequent core policies. The interests'. In connection with paragraph 3 of the policy, Disturbance, I would also recommend document should be read and applied as a whole, that in relation to suitable mitigation measures ‘will' should be replaced with ‘may'. Furthermore and individual polices should avoid repetion and in point i I recommend substituting ‘contributing to' in place of ‘securing'. Making specific duplication where possible. No reference is made recommendations for specific species at this time seems in many ways to limit the mitigation to the protection of nationally important sites, as focus to just those species and it might be advisable, and more flexible, to use them as this is provided by the national policy framework, examples rather than specifics. In paragraph 6.5.4, second sentience I would recommend which should not be duplicated. Suggestions for Biodiversity, inserting ‘heritage, landscape, and' between ‘relevant' and ‘ecological'. The AONB advises wording noted and considered in redrafting the landscape, that the supporting text in paragraph 6.5.7 for Core Policy 34 Landscape should be policy. References to landscape functions and 2092 heritage, SO5 strengthened by the reference to landscape functions, such as provision of open spaces, ELC added to CP51. Some confusion over the green woodlands, fields, places to live and work, and to refresh the spirit.. It would also be appropriate purpose of the landscape strategy which has infrastructure to add in to this paragraph the need for local policies to ensure the conservation and been clarified in CP51. The management plans enhancement of the natural beauty of AONBs in addition to policies for the general are too broad for development to be required to conservation of other countryside and locally cherished landscapes. This would also be the strictly comply with them. References to place to refer to the duties under the European Landscape Convention as well as referring to landscape sensitivity studies, tranquillity studies the importance to protect, conserve, and enhance landscapes for their own right. Indeed the and historic landscape characterisation to be overarching importance of landscape to Wiltshire, and the relationship of this Core Strategy to included. Further clarity over the setting to be the European Landscape Convention (signed by government on behalf of the United Kingdom included within supporting text. The GI issues in 27), should, we recommend , mean that Landscape is the first policy under Strategic have been addressed through further workshops Objective 5. The ELC requires landscape to be incorporated into strategic plans and policies involving the AONBs. as well as putting landscape management and landscape training duties on the nation. Without these ELC elements the Core Strategy could be unsound. Policy 34 should, I strongly recommend include reference to location, topography and landform in addition to those elements already identified. Furthermore, the policy should be much more robust than simply having regard to the relevant AONB Management Plans; it should be worded ‘would need to comply with' the relevant Management Plans of these areas. I am also concerned that there may be some misunderstanding about landscape character assessments exhibited in paragraph 6.5.9 as it is not really feasible to consolidate a variety of landscape character Cross Comment No. Comments Officer Comments Issue Reference By assessments into a single one since they have been prepared at different scales for different purposes. There may, however, be scope for landscape management guidelines that flow from landscape character assessments, and it would also be more correct to note that landscape sensitivity studies, and landscape characterisation work ‘are' relevant (rather than ‘may be'). Furthermore, changing ‘historic landscape characterisation work' to ‘historic characterisations' as an additional aspect, will provide greater flexibility to include studies such as the forthcoming ‘Wiltshire Historic Farmstead Characterisation'. In 6.5.1 it is, I strongly suggest , appropriate to add in ‘national' in front of ‘significance' in the first sentence. Furthermore in paragraph 6.5.11 the first sentence should be more specific about being expected to comply with Management Plans rather than simply having regard to them. It would also be appropriate to include landscape sensitivity and tranquillity studies in the examples listed. In relation to the setting of the AONB the text is correct in saying that it is not precisely defined but it might be useful to provide a footnote or appendix reference to PPS5 where there is quite a lot of material relating to setting. In connection with special landscape areas there seems to be a typographical error in the second bullet point. The discussion in paragraph 6.5.14 seems to have overlooked the fact that Green Infrastructure provides a mechanism for retaining recognition of locally cherished landscapes and that this is one of the additional benefits deriving from the Green Infrastructure concept. Furthermore, paragraph 6.5.2 does need to be given an overarching and conceptual basis for Green Infrastructure otherwise it is merely a list of northern Wiltshire's accessible, recreational, and wildlife areas that are physically linked together whereas the concept is much more holistic and focused on landscape spaces and functions. That provides a much more useful working concept and I am confident the AONBs would be happy to be involved in the preparation of a more holistic approach to Green Infrastructure. At the current time I am not aware of the AONBs being brought into this important issue. The involvement of AONB teams is particularly pertinent as Green Infrastructure can be a significant influence in achieving a sustainable visitor economy. Thank you for yourletter dated 8 June 2011 regarding theCore Strategy Development Plan Document published by Wiltshire Council. Please note the comments outlined below, which aremade on behalf of Wessex Water acting as the water and sewerage undertaker for the Wiltshire area. Proposals allow for 37,000 new homes and approximately 180 hectares of employment land to the period 2026. There are specific vision programmes for the principal settlements at Salisbury, Trowbridge & Chippenham and identified growth plans for the market towns within Wiltshire. These proposals are supported though adelivery strategy for strategic sites and community led plans with emphasis upon linking residential sites with employment growth. There are a number of areas where Wessex Water can contribute to the proposed plans and policies and it is recognised that development proposals will need to be supported with appropriate infrastructure. Water and sewerage services are recognised as critical infrastructure and feature in the Core Policy 3 for Infrastructure requirements. This approach will allow the consideration of the impact upon existing infrastructure and the planning of Comments from Wessex Water noted. Support capacity improvements for networks and treatment resources. Wessex Water is willing 2095 for and involvement in the infrastructure planning Question 3 toundertake and participate in any relevant appraisal work to identify future improvements process appreciated. required to servenew development. This will include assessment of foul and surface water drainage networks andwater distribution systems which can be included in the development management process during masterplanning. The cumulative effect of development proposals can beassessed toconfirm strategic improvements required to match the level of growth withinwater and waste catchments. Capitalinvestment programmes can be implemented to match phased requirementsand the rate of development. Strategic objectives Policy SO9 : to ensure that infrastructure is in place to support our communities. This includesthe preparation of separate Infrastructure Delivery Plans which will be subject to furtherconsultation with stakeholders later this year. New developments should ensure that suitable provision is made for strategic sewer routes and separate systems of drainage will provide opportunities to reduce flood risk to downstream propertiesby promoting Sustainable Urban Drainage systems . Future provision is being made under the Flood and Water Management Act 2010 for approving and adopting Sustainable Urban Drainage systems. Policy SO10: to minimise the risk of flooding Cross Comment No. Comments Officer Comments Issue Reference By and ensure effective water management. The flood risk issues addressed in PPS 25 primarily relate to land drainage, however sewerage infrastructure and its capacityforms an integral part of this assessment. Water efficiency is considered in the Code for Sustainable Homes (CSH) which providesa standard for new homes and will assist in reducingdemand. We also note Core Policy 51 regarding pollution andphosphates levels and proposals for a Nutrient Management Plan. If any further information is required or clarification is needed, please call me to discuss.

Topic Paper 17: Housing Requirement Technical Paper, shows that the proposed housing requirement of 37,000 dwellings was selected as being on the low side of the mid-range (between 35,900 and 43,200). Given that household projections, affordability indicators, and economic development forecasts all clearly support a higher range than that tested, the justification for adopting a lower range (and then selecting a final figure on the low side of that range), appears to rest with concerns about the ability of the market to support increased levels Noted - National policy, particularly in the form of of delivery on the one hand and about environmental capacity on the other. Neither of these PPS3 & PPS4, states that through the Core concerns are justified. The underlying assumptions about housing delivery rates are unfounded Strategy the council should promote greater and, in any event, do not justify a substantial restriction in the level of housing provision levels of development at settlements with the planned. In considering deliverability, PPS12 advises that deliverability should be concerned facilities and infrastructure to support that with infrastructure delivery, regulatory or national policy barriers and agreement with partners development and provide the best opportunity to who are essential to the delivery of the plan, including landowners and developers. The Core offer jobs and homes in the most sustainable Strategy should, therefore, plan to meet the identified housing need and demand first and manner. The designation of the principal foremost and should not be led by concerns about achieving house building rates, particularly settlements allows the best opportunity for 2096 when the house building industry does not accept or share those concerns. Topic Paper 17 Wiltshire to fulfil its requirement for jobs and Question 2 also justifies the low housing requirement on the assumption that additional housing sites, over homes within environmental limits. Topic paper and above the 37,000 requirement, will be delivered through unidentified windfall sites and 17 paper sets out the progress made in additional locally identified housing sites. This view would indicate that the Local Planning determining an appropriate requirement and Authority consider that the housing requirement identified in the Core Strategy should be largely distribution of housing for Wiltshire from 2006 to met through additional housing allocations to be identified in the Site Allocations DPD, rather 2026 to inform the draft Wiltshire Core Strategy. than through windfall sites. However paragraph 5.0.13 of the Draft Core Strategy conflicts with This process considers the strategic objectives for this approach, as it indicates that the non strategic residual requirement identified for each the county as well as taking into account local community area includes windfall sites. That is contrary to PPS3. Sites must either be identified factors and aspirations for growth identified as strategic sites or sites must be identified in a subsequent site allocation DPD (or through community consultation. neighbourhood plan) providing that an adequate 5 year land supply can be demonstrated from specific deliverable sites. Unless this is done, it is impossible to assess how much provision is actually required to be provided in the site allocation DPD (neighbourhood plan). If Wiltshire Council were to allow all housing on windfall sites there would be no allocations made at the DPD. To have such an uncertain spatial strategy is unsound. We act on behalf of Bloor Homes Ltd who is currently developing the Archers Gate housing site on land to the south of Amesbury and who is also promoting the King's Gate strategic housing 2099 allocation on land adjacent to Archers Gate through the South Wiltshire Core Strategy. We Noted Q22 have reviewed the draft Core Strategy and wish to make the following comments. [comment nos. 2100, 2102, 2103, 2104, 2105, 2106 & 2107] Cross Comment No. Comments Officer Comments Issue Reference By

Core Policy 43: Transport and development We welcome the objective to reduce the need to travel and encourage the use of sustainable transport alternatives. However, where a contribution is sought towards transport improvements it must be set out in a planning Support noted. Infrastructure LDF and CIL 2107 obligations DPD which is examined as part of the LDF process, and / or meet the tests of charging schedule will be prepared in line with SO8 Circular 5/25 as amended by the CIL Regulations 21, i.e. it must be: (g) "necessary to make the national policy. development acceptable in planning terms (h) directly related to the development; and (i) fairly and reasonably related in scale and kind to the development"

I write on behalf of my client, Ashtenne Industrial Fund Limited Partnership (‘AIFLP'), to submit representations to the Core Strategy Consultation document. AIFLP is the freehold landowner of the Langley Park estate located on the northern edge of Chippenham town centre and a key regeneration site for the Core Strategy. These comments should be read along side our submission to ‘Wiltshire 2026 - Planning for Wiltshire's Future' made in December 2009. 2117 Wiltshire Core Strategy AIFLP supports the Council's vision to strengthen communities by Noted Q22 maintaining and increasing the supply of jobs. Developments should ensure that communities have a balance of jobs, services, facilities and homes and should be sustainable and of a high quality. AIFLP trusts that the matters raised within this letter will be incorporated into the Core Strategy as it moves forward. It also looks forward to working with the Council and the Chippenham Vision Board on the Chippenham Central Area Masterplan.

Core Policy 45 - Transport strategies AIFLP notes the reference to integrated transport measures for Chippenham and supports the general principle that sustainable transport will facilitate sustainable growth. AIFLP also notes the reference in the policy to developer Support noted. Infrastructure LDF and CIL 2125 contributions and considers this to be a reasonable aspiration. However, the policy also needs charging schedule will be prepared in line with SO8 to acknowledge that the aspiration for integration transport measures should not be at the national policy. expense of development viability and the contributions sought from developers should be in line with the content of the CIL regulations and an appropriate CIL charging schedule.

The consultation process is flawed. The housing and industrial development proposed to the South West of Chippenham is not actually part of the Chippenham Area but part of the Corsham Area - more specifically Corsham and Lacock parishes. The Consultation document only mentioned the development in the Chippenham area sections from 5.1 and not in the Comments noted. The proposals for South West Corsham sections from 5.7. Anyone looking at the Corsham area sections alone would be Area of Search were not shown in the Corsham totally reassured by such comments as: "Lacock village, a popular tourist destination" (5.7.1) Community Area section. Agree to amend map and "Corsham has not been identified as a location for new strategic employment growth" 5.10 in future. However, it is not agreed that the (5.7.3). Core Policy 11 - Spatial Strategy: Corsham Community Area (page 74) says: consultation was flawed. Site selection process "Development in the Corsham Community Area should be in accordance with the Settlement and analysis of sites is set out in Topic Paper 14. Lacock; Site 2131 Strategy set out in Core Policy 1: Market Towns: Corsham Large Villages: Colerne and Box The evidence now presented provide best Selection; Chippenham Small Villages: Gastard; Lacock; Neston; Rudloe and Westwells. 3.3ha of employment land will solutions to accommodate sustainable Employment be provided." This is totally untrue. The site at Showell, in Lacock parish, is for 28ha of development at the town in light of the emphasis industrial development/employment land. Core Policy 11 continues: "Over the plan period on the delivery of employment land to develop the (2006-2026), 1200 new homes will be provided of which 1,050 should occur at Corsham. 150 strategic employment role of Chippenham and the homes will be provided within the rest of the community area. There will be no strategic housing proposed reduction in the overall number of or employment allocations in Corsham." This too is totally untrue: The Patterdown sites are in homes to be provided during the plan period. the Corsham area and a site of 1500 homes is clearly a strategic housing allocation. The council appears to have acknowledged the consultation was flawed. At a meeting in Lacock, on July 19 2011, Georgina Clampitt-Dix, Head of Spatial Planning, admitted it was an oversight. Cross Comment No. Comments Officer Comments Issue Reference By During the course of the evening Alistair Cunningham, Director of Economy and Enterprise, said that other options had been considered. Development at Showell and Patterdown was now the preferred option hence the consultation. He admitted there were still other options but these were not part of the consultation. How can a consultation be fair when only one option is on the table but others exist which can't be discussed? This view is shared by those in favour of development to the East of Chippenham. While admittedly an interested party Edward Heard, Managing Director of Chippenham 2020 LLP, asked Wiltshire Council's Cabinet on 24 May 2011 to include the original preferred option in the consultation. In a document ahead of the meeting he stated: "Given this is the final public consultation stage, before the preparation of the Pre-Submission Draft Core Strategy in the Autumn, Chippenham 2020 consider that the proposed consultation, as currently drafted, would seriously prejudice fair and open consideration of the East Chippenham development option." ( http://cms.wiltshire.gov.uk/mgConvert2PDF.aspx?ID=18614 ). There is a distinct lack of clarity about what the consultation is actually about. Core Strategy 5 Options 1 and 2 contains maps (5.3) and (5.4) showing the proposed sites. Both maps show exactly the same development area to the South West of Chippenham where two developers are actively interested. Option 1 is for 1,500 dwellings and Option 2 is for 800. Since the smaller site at Hunters Moon can accommodate 800 homes and the larger site several thousand it seems one or other site should have been the preferred option for Option 2 and the maps should reflect this. Map 5.3 is erroneous in the strategy document by missing the North East Chippenham employment land. A corrected map was put on the website but the faulty original document was not amended and remained throughout the consultation. Not only is the Map erroneous but fundamental documents are missing from the consultation section of the website where residents are invited to leave their comments. The Supporting Documents tab does not include or even signpost the fact there are a variety of topic papers full of information which have enable the Council to draw their conclusions. Without even knowing about these documents the lay-person is put at a significant disadvantage in coming to any kind of informed opinion. The inclusion of the new development area in the South West appears to have come about due to the responses from the earlier consultation which benefitted from discussion at several public meetings. The only public meeting which discussed the new Options 1 and 2 was not organised by the Council and was totally packed. It has not had the same amount of public scrutiny. On top of this the consultation period has run far into the holiday season which may mean many people may have been unaware of it and not been able to contribute. This consultation has run from June 16 to August 8 - a total of 54 days. The previous consultation ran from 30 October to 31 December 2009 - a total of 63 days. "The consultation included 4,000 direct consultees, including community groups, 17 exhibitions across Wiltshire and 15 workshops. In addition, we met with town and parish councils and documents were provided to elected Wiltshire councillors. We received a total of 2,192 individual responses from 678 respondents. The number of consultees, the broad range of organisations and individuals involved and their geographic spread across the county gives confidence that the results can be considered to be representative." (5.0 Executive Summary Wiltshire 2026 Consultation Methodology and Output Report August 2010). I don't think it is possible to say the same about this consultation. In summary: 1 Residents in Corsham Area were not told of the scale of the development affecting them, in fact they were told the reverse, one might even say they were misled. 2. The Council has other options on the table but the public can't discuss the alongside one another. 3. The Chippenham Option 1 map (5.3) was wrong and not amended in the consultation document. 4. The Chippenham Option 2 map (5.4) shows the same area being developed regardless of whether 850 or 1500 homes are to be built. 5. Topic papers containing vital detail are not with Supporting Documents on the consultation part of the website despite their importance. 6. The consultation period is shorter than the previous one, runs into the holiday period and was not accompanied by meetings organised by the council to explain the proposals. Not really a very fair consultation after all. Cross Comment No. Comments Officer Comments Issue Reference By

I write to respond to Wiltshire Council's consultation on the Draft Core Strategy for Wiltshire, hereafter the Core Strategy. This written response is further to the meeting we had at the Council's Monkton Park Offices, and the representations I made in person in the earlier Core 2141 Strategy consultation round. I recognise this consultation is only the latest stage in a Noted Q22 necessarily lengthy process to decide the future planning policies for Wiltshire, but believe that the coming few months will prove critical. I would therefore appreciate a direct response to these concerns before councillors are asked to agree a further set of proposals.

For all settlements - We recommend the document should provide a clearer map in each of the settlement sections to highlight the location of the preferred sites and constraints for each settlement policy. We note from paragraph 6.10.1 (page 164) that there should be sufficient land available in Flood Zone 1 to meet the proposed housing requirement for Wiltshire. We Noted. A set of revised maps will be produced for 2155 would therefore expect this to be reflected in each of the Community Areas. However, if any the next draft of the Core Strategy. The Maps Q22 development, including industrial/ commercial, is proposed in Flood Zones 2 or 3, a Sequential respondents comments will be taken into account. Test in accordance with Planning Policy Statement 25 would need to be undertaken. If any of these sites are to be strategic allocations in this Core Strategy, then a Level 2 Strategic Flood Risk Assessment would be required as part of the evidence base.

Core Policies 37 to 48 - No comments, apart from noting we support the principles of Core 2174 Policies 42-47 to reduce the need to travel and encourage the use of public transport and other Support noted. SO8 non-car based travel. Glossary (page 167 onwards) We note that the Environment Agency is not included in the list. Noted. Comment will be taken into account when 2176 We recommended the inclusion of us in the Glossary may be useful for the readers of the Core Glossary Q22 updating the Glossary for the next draft. Strategy.

Sustainability Appraisal Provided that the Sustainability Appraisal (SA) addresses the points mentioned in our letter we would be satisfied with the evidence base. For example - a) Noted. These assessments are being carried out reviewing Core Strategy against River Basin Management Plans covering Wiltshire (WFD); b) 2177 and form part of the essential infrastructure for SA Q22 carrying out any required Level 2 SFRA work - if developments are to be in FZ2/3, or if there these Community areas. are other known flood risk issues (eg Warminster); c) foul drainage capacity associated with Tidworth/ Ludgershall. Thank you for the opportunity of commenting on the core strategy consultation document. My views have been informed by discussion with a number of individuals and authorities. My first observation on process is that the document is not easy on the reader. There is imprecision in The comments regarding the legibility of the the use of words and much jargon. For example, the authors assert repeatedly that the plans document and the general principles are noted. are ‘sustainable.' How so? In fact, much of the document's controversial material involves The majority of the comment focuses in part on building on agricultural land, particularly in west Wiltshire. I would look for discussion in terms of west Wiltshire and the three market towns. damage limitation and remediation before agreeing that a plan was sustainable. At the risk of Comments regarding town centres and being pedantic, I would avoid the strategy's hand-wringing over commutes outside the Trowbridge, employment are noted. Core policy 6, 8 & 18 Number of 2180 administrative county boundaries; what it calls out-commuting. Politicians and local government Westbury & Q22 have detailed plans for regeneration of Issues officers may think in these terms but the public does not. If the didactic approach apparently Warminster Trowbridge and Warminster town centre adopted in pursuit of being green is accepted it would mean travel from Bradford-on-Avon to respectively. Nevertheless comments regarding work in Salisbury is good but to Bath is bad. A more useful planning consideration is travel to schools, the west Wilts trading estates and other work time. The timeframe for consultation has been tight, particularly since key documents aspects particularly Yarnbrook are noted and appeared late and the procedure has run over the summer holiday period. Turning now to the have passed on to the relevant officer. substance. Whilst the document holds merit, I have significant concerns overall. It is difficult to find fault in the trailblazer ‘key principles.' The need to facilitate high quality employment and to increase the provision of affordable housing for local residents is clear. However, the abolition Cross Comment No. Comments Officer Comments Issue Reference By of the RSS has offered an opportunity to think imaginatively about how the wellbeing and quality of life of residents can be enhanced. It is not clear to me how the proposals based on ‘strategic growth' will achieve this. For example, we learn that ‘strategic growth' on fields to the south-east of Trowbridge will deliver ‘significant and focussed' improvements to the A350 at Yarnbrook and West Ashton. The mechanics are not explained and the reader is left with the suspicion that extraordinary growth in housing and edge of town employment ‘sheds' will simply deliver more congestion which the strategy rightly points out is already bad. A further example of a lack of granularity is the assertion that a school is needed to the south-east of Trowbridge. A new well-resourced school would indeed be most welcome but there is significant controversy over the means of improving secondary education in BA14 with many residents believing that investment in existing schools would be a better option, notwithstanding the geography. No mention of this is made. In my view, the strategy puts insufficient emphasis on imaginative use of derelict and previously used sites, particularly in the county town. My straw poll of residents produced a strong reaction in favour of development of the town centre before consuming more countryside. It has also been pointed out that many business and industrial units in west Wiltshire, across the cost spectrum, are vacant. The need for more ‘sheds' to accommodate a small number of jobs that are likely to be relatively low skill and low wage, serviced by lorries on the district's inadequate roads unrelieved by the previously anticipated A350 Westbury bypass is unclear. On reading the proposals, my constituents in BA14 may well conclude that a disproportionate burden of the strategy's housing and employment land designation has been put on them. It is not clear why this should be. Part of the reason could be the strategy's insistence that Trowbridge should rank with Salisbury and Chippenham as a ‘principal settlement'. This is all very well except the cathedral city's infrastructure is much superior to that of the county town. Chippenham's transport links and Salisbury's size, geography and facilities make them more obvious candidates for growth than Trowbridge. The county town might feel that it is being ‘dumped on' and that any improvements in infrastructure, if they materialise, will lag well behind the proposed construction. The proposals will result in the loss of the village identities of North Bradley, Yarnbrook and West Ashton which will then constitute the fringe of Trowbridge with a consequential change in the nature and feel of the county town's existing residential margins. There is a need for more affordable housing in Warminster as elsewhere and I support its construction but, although it is difficult to make an accurate assessment given the way the data has been presented, the allocation of 900 homes to Warminster looks like the highest for any of the settlements designated ‘market towns' in the strategy. It is not clear why this is. The strategy rightly says that house building in Westbury has outstripped provision of infrastructure. Its remarks about the high street will also strike a chord with residents. However, 5.18.7 talks ambiguously about achieving an ‘organic street pattern.' I do not know what this means since it goes on to say that the high street should have mixed uses (residential and retail) which it already has. The reader is left speculating on what the authors have in mind and how they will achieve it, The strategy wants to improve on jobs in ‘existing low quality trading estates' and asserts that ‘strategic growth' will deliver ‘skilled jobs.' I suspect that the authors have sites like the West Wilts Trading Estate in mind. However, units in such developments have large numbers of skilled individuals working in specialist undertakings in the manufacturing and service sectors. It should not be assumed that the sorts of jobs likely to be available in new shed-type accommodation will be of higher quality. The authority will no doubt wish to review the core strategy in the light of the government's announcement this week of a new approach to car parking that is more helpful to market towns and the shortfall in anticipated parking revenue. Small businesses and my constituents in and around Trowbridge, Westbury, Warminster, Mere and Tisbury stand to benefit from this government's less hostile approach to road users. I have avoided a detailed critique of the strategy but, on travellers and gypsies (6.3.23), wonder why only six pitches have been identified in east Wiltshire out of the 93 proposed for the county overall. On the River Biss, I approve of the ‘corridor' envisaged. However, it seems to me that the Biss amenity will deteriorate after it is boxed in by the employment and housing designations south-east of Trowbridge. I hope my remarks are helpful. Cross Comment No. Comments Officer Comments Issue Reference By White Lion Land LLP has been promoting land west of Malmesbury (the Subject Site) for housing development since review of the North Wiltshire Local Plan (adopted June 2006) began in February 2006. The now unified authority for Wiltshire is formulating a Core Strategy for the plan period 2006 to 2026. The Council invited comments on the “Wiltshire 2026 - Planning for Wiltshire's Future” document dated October 2009 which set out the “direction of travel” for the emerging Core Strategy. Following review of the consultation responses and other matters, the Wilshire Core Strategy Consultation Document (WCSCD) was published for consultation on 13 June 2011. This sets out, inter alia, the proposed housing strategy for Wiltshire including the number of dwellings to be delivered over the plan period and a settlement strategy. This is a formal consultation stage concerning preparing the Local Development Framework. The Council anticipates that following review of WCSCD consultation responses that a Submission Draft Core Strategy will be published for consultation towards the end of 2011. The representations address WCSCD generally and Malmesbury in particular. Basis of Wiltshire Core Strategy Consultation Document – Chapter 1 The WCSCD has been prepared predominantly in the context of the emerging Localism Bill which proposes changes to the planning system including the abolition of Regional Spatial Strategies and the introduction of Neighborhood Plans (WCSCD – Chapter 1). None of the strategies contained within the WCSCD are based on the regional tier of the development plan and there is a significant reliance on future Neighborhood Plans to deliver important strategic objectives. We object to this approach as point of principle as set out below. The Secretary of State issued “The Planning System: General Principles” on 31 January 2005. It identifies the hierarchy of the plan led system as National Planning Policy Statements; Regional Spatial Strategies and Local Development Frameworks. The Planning and Compulsory Purchase Act 2004 requires Local Development Frameworks to have regard to national policies and guidance issued by the Secretary of State and also to be in general conformity with the RSS. These are the foundations of the plan making process which local planning authorities are required to follow. The Council is preparing the document as far as Wiltshire Council has not done so in preparing the WCSCD. 2 These provisions are also clearly possible in line with the Localism Bill as adoption 2198 RSS Q22 set out within PPS12 “Local Spatial Planning” dated 4 June 2008. Paragraph 3.1 of PPS12 of the bill is expected to take place in advance of states that the development plan is made up of the Regional Spatial Strategy (RSS) which the Core Strategy. covers the whole region and Development Plan Documents (DPD) produced by local planning authorities within the local development framework (the Core Strategy being the principal DPD). Paragraph 4.5 of PPS12 identifies that it is a legal requirement that the plan has regard to national policy and conforms generally to the RSS. Paragraph 4.6 states that to be “sound” a core strategy should be justified, effective, and consistent with national policy. Regional Spatial Strategy for the South West covering the plan period 2006 - 2026 (as a replacement for RPG10 and the Wiltshire Structure Plan) reached an advanced when proposed changes following an Examination in Public were published in July 2008 (draft RSS). Whilst the draft RSS has not proceeded to adoption, it should be afforded significant weight as part of the development plan due to the advanced stage it has reached. The Localism Bill was published on 13 December 2010 and provides, inter alia, for the revocation of the RSS tier of the development plan and introduction of Neighbourhood Plans to the development plan hierarchy. Letters from the Department of Community and Local Government (DCLG) dated 27 May and 10 November 2010 relate to the materiality of the government’s intention to abolish the RSS regime. The issue of materially has been tested in the Court of Appeal, the most recent judgement on which having been handed down on 26 May 2011 (Cala Homes (South) Ltd v. Secretary of State for Communities and Local Government & Another [2011] EWCA Civ 639). The appeal was dismissed on the basis that the intention to abolish the RSS tier could be treated as a material consideration. However, the Court of Appeal determined, so far as development management/control decisions are concerned, that only limited significance or weight might be reasonably attached to provisions of the Bill as it progresses through Parliament and pending the outcome of the process of Strategic Environmental Assessment (SEA). The Court of Appeal emphasised that the statutory requirements were markedly different and less flexible in respect of the production of local development documents: This “valuable element of flexibility” (see Lord Clyde‟s speech in the City of Edinburgh case cited in para. 6 above), given to the local Cross Comment No. Comments Officer Comments Issue Reference By planning authority when determining planning applications, is to be contrasted with the lack of flexibility when the authority is preparing its development plan documents. It must have regard to the relevant regional strategy (among other specified matters), and whether or not it is precluded from having regard to other matters which are not listed in paragraphs (a)- (j) of section 19(2) of the 2004 Act, the end-product, the local development documents, “must be in general conformity” with the regional strategy: see section 24(1) of the 2004 Act. Development plan documents must be submitted for independent examination by a person (in practice a Planning Inspector) appointed by the Respondent, and one of the purposes of that examination is to determine whether the development plan document satisfies the 3 requirement of general conformity in section 24(1). It would be unlawful for a local planning authority preparing, or a Planning Inspector examining, development plan documents to have regard to the proposal to abolish regional strategies. For so long as the regional strategies continue to exist, any development plan documents must be in general conformity with the relevant regional strategy‟ (paragraph 24; underlining added). It will be recalled that this arose in the context of submissions from Stevenage Borough Council arising in respect of its Core Strategy and the reference to „any decisions‟ in the letter dated 27 May 2010: „However, the written submissions of Stevenage Borough Council which was given leave to intervene have identified one respect in which the reference in the letter [deted 27 May 2010] to “any decisions” was potentially confusing. Stevenage is preparing its development plan documents. Those documents include a Core Strategy which has been submitted for independent examination. The Planning Inspectors‟ report is awaited. There has been correspondence between Stevenage and the Planning Inspectorate as to the effect of the purported “abolition” of regional strategies in July 2010, and their “reinstatement” in November 2010 following the decision of Sales J. The detail of that correspondence is not relevant for present purposes, but the fact that there was an exchange of correspondence demonstrates the need to make it clear that the reference in the letter to “any decisions” is a reference to development control decisions; it is not a reference to decisions by local planning authorities and the Planning Inspectorate in the preparation and examination of development plan documents: see para. 24 (above) ‟ (paragraph 28). The Draft Core Strategy and supporting papers proceed throughout on the basis that RSS will be/has been abolished1 and without regard, as we see, for the requirement for general conformity (indeed, one of the key themes is that the Core Strategy represents a significant departure from draft RSS in terms of housing provision); and it appears to us that the Council is acting unlawfully in formulating its Core Strategy in this way. The inadequate discussion of the Cala Homes litigation in the WCSCD Glossary of terms suggests that the Council has not acknowledged or given effect to the judgment of the Court of Appeal cited above. A fortiori, it has afforded too much weight to the provisions of the emerging Localism Bill within the WCSCD by choosing to ignore requirements of the draft RSS and by placing significant reliance on Neighbourhood Plans to deliver its strategic objectives. To pre-judge the final content of the Localism Bill at its current stage and before conclusion of the SEA process does not provide a sound basis on which to seek to proceed to examination of the soundness of the Core Strategy for Wiltshire. 1 See for example: „In light of the intention to formally abolish regional spatial strategies the council has sought to review the level of growth identified within the draft south west regional spatial strategy.‟ (Topic Paper 2 paragraph 2.13). 4 The errors implicit in this flawed approach are compounded by recent publication, by the DCLG, of the draft National Planning Policy Framework (NPPF) for consultation on 25 July 2011. This seeks to bring all national policy together within a single document that will eventually replace all Planning Policy Statements currently in force. The draft NPPF seeks to establish a presumption in favor of development that will run through plan-making and decision-taking (Para 14). Whilst on consultation at present the provisions of the draft NPPF are a material consideration. Certain aspects of the WCSCD, including the provision for a 5 rather than 6 years supply of housing land, will be inconsistent with national policy as the NPPF proceeds towards adoption (assuming that that key proposal remains (see Para 109)). As currently drafted the WCSCD it is already out of date and should be reviewed in the context of the draft NPPF. In summary, therefore, the WCSCD has not been formed on a basis that is legal or sound having regard to Cross Comment No. Comments Officer Comments Issue Reference By the framework of the plan led system established by the Secretary of State and the Planning and Compulsory Purchase Act 2004 (as to which the Council has been on clear notice since judgment was handed down in the Cala Homes appeal), and current national policy guidance contained within PPS12. The further representations below are submitted without prejudice to our conclusion that WDSCD should be withdrawn (withdrawal should not await the intervention of the Inspectorate upon submission). Wiltshire Overview – Chapter 2 Chapter 2 of the WCSCD provides an overview of Wiltshire which sets a context for the draft policies contained within the plan. We do not raise any objection to the facts set out within this chapter but consider that key elements of the housing strategies set out later in the WCSCD do not go far enough to address key pressures within Wiltshire. In particular we note the following points which we refer to later within this submission: WCSCD – Para 2.12 Housing: i. There is a high demand for housing within the Wiltshire; ii. There is a significant affordability issue due to the desirability of Wiltshire as place to live; iii. Access into the housing market is difficult for many residents due to high levels of demand and deterioration of affordability; iv. There are over 10,000 people of the Council’s housing waiting list 5 Spatial Vision – Chapter 3 We generally agree with the proposed Spatial Vision and Strategic Objectives for Wiltshire set out within Chapter 3 of the WCSCD. We support the provisions of Strategic Objective 3 which aims to provide everyone with access to a decent affordable home. However, the strategic target of around 37,000 new homes within Wiltshire up to 2026 is considerably below that of the draft RSS which requires 43,200 over the same period. Whilst we note that the Council has attempted to provide technical justification for the reduction within Topic Paper 17 - Housing, we also note that the higher level of housing was based on evidence provided by the Council to the regional body when the draft RSS was being prepared. In an area that is affected by high demand and poor affordability, the Council should be looking to maximise the amount of new housing to be delivered within the plan period. There remains robust justification for the higher levels of housing set out within the draft RSS based on population and household projections. The Council will be better placed to tackle the housing challenges within Wiltshire by adopting the higher target set out within the draft RSS. We do not comment on the substantive merits of the level of housing provision proposed because we consider that WCSCD is flawed having regard to its approach to the draft RSS (see above). Having regard to the above considerations [comments 2194 - 2198], White Lion Land raises the following objections to the WCSCD: 1) By ignoring the regional tier of the development plan and placing significant reliance on Neighborhood Plans that currently have no status within the plan led system, the WCSCD has not been formed on a basis that is legal or sound having regard to recent case law and the plan led framework established by the Secretary of State, the Planning and Compulsory Purchase Act 2004 and national policy guidance contained within PPS12. 2) The WCSCD does not reflect provisions of the draft NPPF which is a material consideration. The Council should be looking to identify 20% more deliverable housing sites in order to demonstrate sufficient flexibility within the rolling 5 year land supply and enable choice and competition in the market for land. 3) Proposals to significantly reduce the housing target for Wiltshire do not adequately reflect the level of growth required to meet the challenges of The Council is preparing the document as far as demand and affordability and are significantly below the provisions of the draft RSS which possible in line with the Localism Bill as adoption 2199 RSS Q22 forms part of the development plan. The Council should be looking to maximise housing supply of the bill is expected to take place in advance of to meet strategic objectives and therefore should adopt the higher level of growth supported by the Core Strategy. population and household projections. 4) Identification of strategic sites should not be limited to the principal settlements where there is sufficient evidence available to allocate sites and such allocations will help meet core strategic objectives. The Council should be looking to support the bulk of housing land requirement within the Core Strategy to ensure an adequate and flexible supply of deliverable/developable sites can be identified. To defer such provision to later stages in some parts of the plan area will only serve to continue the delay and uncertainly surrounding delivery of new housing within Wiltshire. 5) Phasing restrictions will not help address the immediate housing need and significant shortage of affordable housing. They would also not consistent with the government objective to encourage growth and economic activity. 6) Greenfield land on the edge of Malmesbury Town is required to meet the identified Cross Comment No. Comments Officer Comments Issue Reference By need for new housing, including affordable accommodation. This issue is central to the Core Strategy and the Council has sufficient evidence available to allocate land (in particular land off Park Road) without delaying progress. To defer such allocations is contrary to national policy and current government objectives to stimulate development. 7) A phasing policy that may limit the ability to grant planning permission for major housing development will also restrict the ability to move forward with plans to improve educational facilities. The allocation of housing sites within the Core Strategy would provide greater certainty about funding for infrastructure projects. The capacity of primary schools should therefore not be presented as a reason to delay site allocations on the edge of Malmesbury town. We trust that these will be treated as duly made representations as part of the ongoing preparation of the Wiltshire Core Strategy.

MWEP welcomes the strategic focus of the Core Strategy proposals with its commitment to maintaining and increasing the supply of jobs to ensure that Wiltshire remains strong and 2213 Support noted. Chapter 1. Q22 prosperous. (1.3) The key principles, which underpin the proposed strategy, are fully supported. (1.4)

Understand the point, but to be effective these Page 18 bullet point 2 states - "where appropriate, existing employment sites will have been 'criteria' should be included within a policy. Policy 2214 protected". The bullet point needs to state the criteria for what is deemed ‘appropriate', is this Chapter 3. Q22 has been developed later in the strategy which related to the site, the employment activity or the circumstances of the protection decision. does just that. Comment noted. It will considered whether more The document should include policies related to the de-allocation of sites. If land is not coming detail is needed to make it clear which sites will 2215 SO1 forward and a more appropriate use is identified, a policy should be in place to support this. not continue to be saved by the Wiltshire Core Strategy. The rail network is listed in Core Policy 48 and We are concerned that there is insufficient reference to transportation and accessibility issues. comprises part of the Strategic Transport 2221 Core Policy 48 - The Trans Wilts Rail network needs to be mentioned within this policy. This Network. The transport and accessibility policies SO8 route provides an opportunity to promote sustainability - paralleling the A35 corridor. will continue to be developed, including the results of further transport modelling work.

When the Core Strategy was originally put to Warminster Town Council in 2009, the Council put forward its responses in a letter dated 17.12.09 (attached). The Town Plan Working Group has considered the Core Strategy document that is currently undergoing public consultation until 8 2225 th August, and does not feel that there is a need to submit the document to the Council for CP18 Noted. Support welcome where appropriate. General Warminster further comment. Although the working group cannot formally represent the Town Council, it has seen nothing in the current Core Strategy document that conflicts with what was originally agreed. I hope this statement provides sufficient feedback for your records. Cross Comment No. Comments Officer Comments Issue Reference By 3. DISTRIBUTION OF DEVELOPMENT 3.1 The housing requirement is then distributed throughout the various Community Areas as illustrated on Map 1.1 of the consultation draft. 3.2 We have concern on the prescriptive nature of these Community Areas as they are not based on housing market areas. This conflict can be seen from Map 1.1 and Figure 4.5 of the 25th July 2011 SHMA presentation as the housing market areas on Figure 4.5 are much wider than the Community Areas in Map 1.1. If the purpose of the Community Areas is to determine a 5 year supply through disaggregation based on a Community Area we would object as this is directly contrary to the ‘Effective' soundness test in PPS12 which requires flexibility. 3.3 Indeed, the disaggregation of the requirement and supply was dismissed in the appeal decision and Noted - National policy, particularly in the form of subsequent unsuccessful legal challenge at Sandpit Road, Calne. In that case, although a 5 PPS3 & PPS4, states that through the Core year supply could be demonstrated in the rest of the District, the Inspector Strategy the council should promote greater (APP/Y3940/A/09/2108716) gave significant weight to the shortfall of housing within the wider levels of development at settlements with the former district when allowing the appeal. The Inspector recorded in paragraph 18 the Council's facilities and infrastructure to support that acceptance that there is not a 5 year supply in the district and that a supply of only 2.7 years is, development and provide the best opportunity to in fact, a serious shortfall and undermines the Government's commitment, given the current offer jobs and homes in the most sustainable downturn in the economy, to ensuring "...that land supply is in place so that we can deliver manner. The designation of the principal more housing as industry returns to health". 3.4 The Council sought to challenge this decision settlements allows the best opportunity for 2227 through the High Court on the basis that the Inspector erred in law in not applying the Wiltshire to fulfil its requirement for jobs and Question 2 disaggregation of the housing requirement in the structure plan or emerging RSS. That homes within environmental limits. Topic paper challenge was dismissed summarily since it lacked a reasonable basis. Therefore, the 17 paper sets out the progress made in Inspector's conclusions at Sandpit Road that housing need should be assessed district wide determining an appropriate requirement and and not disaggregated was judged lawful. 3.5 Since that decision the need to be flexible has distribution of housing for Wiltshire from 2006 to been maintained. The need for flexibility is also set out in the Ministerial Statement dated 23rd 2026 to inform the draft Wiltshire Core Strategy. March 2011 which states: "(ii) take into account the need to maintain a flexible and responsive This process considers the strategic objectives for supply of land for key sectors, including housing". Wiltshire Council 3.6 The Statement goes on the county as well as taking into account local to say that, when deciding planning applications, account should be taken of "the need to factors and aspirations for growth identified maintain a flexible and responsive supply of land for key sectors, including housing" and Local through community consultation. Planning Authorities (LPAs) should "ensure that they do not impose unnecessary burdens on development". We consider a disaggregation policy to determine housing need and supply in development control decisions based on Community Areas would be a burden on development. For example if a 5 year supply could be demonstrated in one Community Area, yet there is a shortfall in an adjacent Community Area, then planning permission should not be refused. 3.7 Therefore each policy which relates to the housing requirement must be clear that such requirements are a minimum and housing supply will be assessed against a wider area for development control purposes.

Maps contained within the Core Strategy Consultation Document are not adequate as they do not illustrate existing and allocated employment site locations, and do not identify potential Noted. A set of revised maps will be produced for barriers to development. The document should recognise and identify the issues, problems and the next draft of the Core Strategy. The 2242 aspirations of community areas and towns in North Wiltshire, and how they relate to the rest of Maps Q22 respondent’s comments will be taken into the County. Boundaries need to be correctly identified for all the towns and community areas. account. The document should include policies related to the de-allocation of sites. If land is not coming forward and a more appropriate use is identified, a policy should be in place to support this. Cross Comment No. Comments Officer Comments Issue Reference By

Population We note the increase in older age groups in Wiltshire over the plan period, particularly the over 85 age group which has the highest level of care needs. Housing We note the Council's acknowledgement that ‘Affordability of housing is an issue'. We also note that the average house costs 7.5 times the average wage and that currently, the Council's housing list The key challenges will be reviewed and contains more than 10,000 individuals. We understand that the soon-to-be-published updated additional commentary supplied. The Core SHMA for Wiltshire states that there is a net need for 3,862 affordable dwellings per annum. Strategy seeks to maximise the delivery of Given the scale of housing need and affordability problems in Wiltshire we consider that the 2243 affordable housing. Further work will be Chapter 2. Q22 Core Strategy should state that ‘Affordability of housing is an significant issue'. We would also undertaken within the Strategic Housing Market recommend that this is recognised in the ‘Key Challenges' section of the Core Strategy. Assessment and the Viability Assessment to Delivering new homes We note the Council's statement that the Core Strategy should ‘help provide additional evidence. address the general need for housing'. This appears to be an admission that the Core Strategy can not provide enough housing to meet all needs. Demographic Change We strongly support the inclusion of ‘meeting the needs of the ageing population including extra care housing' as a key challenge.

Noted. Infrastructure is an important aspect of Page 4 - Paragraph 1.4 Bullet Point 2 - suggest the word responsive should be replaced with the Core Strategy and an Infrastructure Delivery proactive. Page 4 - Paragraph 1.4 Bullet Point 3 - This should be enhanced to recognise the Plan will be prepared alongside the final core required improvements to road and rail infrastructure. The strategy needs to ensure provision of strategy to ensure that such facilities are appropriate infrastructure for existing and new employment land. Regarding land allocated for 2244 provided. This is now a requirement. Without Chapter 1. Q22 employment and housing developments - have all land owners been engaged by Spatial such infrastructure the council will not be allowed Planning Officers to discuss proposed land usage? There is a lack of overall strategic aims and to take sites forward. The IDP needs to be co-ordination with the points contained within paragraph 1.4 as they are not married to the supported by information from infrastructure points in paragraph 3.2. providers themselves. Core Policy 46 - this policy is unenforceable and should be reshaped or removed. As it stands Further consideration will be given to this policy 2249 SO8 the policy is counterproductive prior to the next draft version of the core strategy. Chapter 3 - Spatial Vision for Wiltshire We are broadly supportive of the Spatial Vision, but consider that it should include the following sentence, given that the Council has identified the need for affordable housing and care and accommodation for older people as ‘Key Challenges'. ‘The supply of affordable housing and the range of care and accommodation options for older people will have greatly increased.' Strategic Objectives We strongly support Strategic Objective 3 ‘To provide everyone with access to a decent, affordable home.' This objective also contains an aim for all developments to meet ‘Safe by Design' standards, we assume this is Agree and subsequent versions will make it clear supposed to read ‘Secure by Design'. There is also no policy later in the document requiring that a range of housing types will have been 2250 Chapter 3. Q22 new development to meet this standard. Notwithstanding this, we consider that the reference provided to help meet local needs for different should be moved from the Core Strategy. We understand that future funding for Police groups , including those of an ageing population. Architectural Liaison Officers is in doubt. This may mean it is impossible to obtain certification for new developments which is a minimum policy requirement. We recommend that the Council includes a policy in a Development Management DPD (or similar document) if funding is secured for Police Architectural Liaison Officers in the future. With regard to the key outcomes, we have a number of comments on the policies related to these outcomes, which are detailed in the following sections.

We welcome the inclusion of Strategic Objective 2: to address climate change, and Strategic Objective 5: to protect and enhance the natural environment. However, the clear links between climate change mitigation and adaptation and biodiversity are not fully addressed. An integrated Agree - subsequent versions will make this more 2254 approach to climate change is essential to ensure that, in the pursuit of targets to reduce explicit and will include detailed polices on how Chapter 3. Q22 greenhouse pollution, we do not lose sight of what the ultimate goal of this activity is - to secure the two objectives need to be delivered together our natural environment and its ecosystem services as well as the social and economic welfare it can deliver in the future. Cross Comment No. Comments Officer Comments Issue Reference By The draft core strategy does not recognise Gloucestershire as an adjacent authority or in terms of macro land use development/ transport issues. This is an omission, as what happens either side of the county border in terms of new development will have an impact on each county's road network. However, it is considered that overall the impacts on Gloucestershire's transport infrastructure from the proposals made in the WCS will be limited. GCC would be concerned about the impact of any development north of the M4 which would increase traffic on the Gloucestershire road network, particularly the A419/A417 which already suffers from high traffic levels and congestion. The WCS proposes limited growth for the Malmesbury CAS, but the Wootton Bassett and Cricklade CAS is proposed for an important employment centre. GCC would expect to be consulted on proposals for any new development likely to generate HGV movements on the County's road network. Wiltshire Council should take account of Gloucestershire's Advisory Freight Route Map and Lorry Management Zone. The proposed development in Malmesbury may also increase demand on parking at Kemble railway station, Comments are noted. The council will continue to however, it is not expected that the proposed development in Wiltshire to be of real significance 2265 work with Gloucestershire as neighbouring SO8 in this respect. Also, the redoubling of the Kemble to Swindon railway line will increase the level authority to ensure these concerns are resolved. of service on the London - Swindon - Cheltenham route. This may increase demand for housing in the area covered by the Malmesbury CAS. Transport Topic Paper This needs to be highly specific e.g. 1.2. ‘land use planning can reduce the need to travel' but not the propensity. Other cultural and legislative tools will have to be developed and approved or centralisation and concentration of development can have the reverse effect to that intended 6.9 implies that the Strategy will develop smarter choices as a solution rather than seeking infrastructure improvements. The level and extent of these commitments should be made clear. The role and extent of smarter choices may impact on both Gloucestershire transport systems and on the need for joint working to secure these shifts. 6.2 Research shows people walking and particularly cycling have a real fear of traffic which may deter them from walking more or cycling at all. The Strategy should recognise the role of cycle training, driver training and promotional measures to alleviate these concerns whether real or perceived. The barriers to walking and cycling are much more than infrastructure and the juxtaposition of new development

Royal Mail Group Ltd (Royal Mail Group) is responsible for providing efficient mail sorting and delivery for Wiltshire. Royal Mail Group, advised by BNP Paribas Real Estate, has reviewed the Wiltshire Core Strategy consultation document for which the public consultation period ends on 8 August 2011. Royal Mail Group sets out below its response to the consultation document. This short response identifies Royal Mail Group's key existing infrastructure in the County. This identified infrastructure is essential to Royal Mail Group in continuing to provide Mail collection 2276 and delivery services to Wiltshire throughout the Core Strategy period. The Royal Mail Group Noted Q22 infrastructure that is identified below and the operations carried out from them will require protection from development and the impact of nearby development. Whilst it is noted that the consultation document is a high level and strategic in nature, it is requested that Wiltshire Council has due regard to the content of these representations in developing the site specific County's Core Strategy. ( For details on current Royal Mail infrastructure, please see attached document )

Traffic capacity Royal Mail Group relies mainly on road transport for all its bulk mail collection and delivery to its facilities. The efficiency of mail handling operations in some existing Royal Traffic assessments will be completed at the Mail Group facilities is very sensitive to changes in traffic capacity in the surrounding highway master-plan stage of planning all new 2284 network. Delays from small increases in congestion can have substantial detrimental impact on SO8 developments with due regard to existing road Royal Mail Group's ability to meet mail collection and delivery timetables. Therefore, in planning uses and congestion. new development, appropriate regard should be had by Wiltshire Council to traffic impact on existing Royal Mail Group operations from its existing infrastructure as identified below. Cross Comment No. Comments Officer Comments Issue Reference By “290 new homes and 3 ha of employment land (on a saved Local Plan allocation) will be delivered to meet needs in the Mere Community Area over the lifetime of this Strategy. It is anticipated that most, if not all, of this growth will be centred on Mere. However, the Strategy is designed to be flexible and has the potential for some of the growth to be accommodated through infill and affordable exception development at Zeals. The identification of new growth sites will be made through the subsequent Site Specific Allocations DPD.” Rural Solutions Consulting comments: The policy set out above allocates the vast majority of new development The SWCS is at a more advanced stage of South South 2290 at Mere and Zeals and disregards the potential for new development (beyond infill) in smaller production. The council is awaiting a binding Wiltshire Wiltshire settlements. This is a significant oversight which ignores not only the opportunities presented at report from the planning inspectorate. smaller settlements but also their current and future needs to create sustainable communities. We note that it is the role of the planning system to deliver sustainable development and that truly sustainable development involves tri-partite consideration of social, economic and environmental sustainability. The concern with the policy above is the overemphasis placed on environmental concerns for smaller settlements which is to the detriment of their future social and economic sustainability. The following refers to the Consultation Proposals overall The Core Strategy proposals are understandably concerned with the identification of sites for new housing and a widened range of sustainable employment opportunities. However there is minimal explicit reference to wider aspects of attractive living conditions - for instance, a need for easy and sustainable access to a range of formal and informal leisure activities. We believe that omission of leisure as a specific topic is a significant weakness within the Core Strategy. There is, we believe, a compelling need to build upon the considerable progress already made by Wiltshire Council (and its immediate predecessors) in developing a range of leisure facilities, and to include proposals for the further development and enhancement of current achievements within the Core Strategy. The Kennet & Avon Canal runs East to West across the heart of Wiltshire, combining past history with modern-day leisure facilities. The Kennet & Avon Canal Trust is therefore surprised at the omission of any reference to this historic waterway within the Core Strategy. This is particularly disappointing as Wiltshire Council (together with its immediate predecessors) has already played a significant part in encouraging restoration of the once- derelict canal and continues to take a leading role in ensuring the upkeep of the restored waterway. The only significant reference to leisure locations within the Consultation Document is to the "honey pot" archaeological sites at Stonehenge and Avebury. This appears to reflect a The June 2011 consultation document includes very narrow and formal view of leisure priorities. We would have expected to see mention made the proposed core policy 41 on retail and leisure. of a much wider range of sites. These should include (inter alia) the impressive group of canal Leisure. 2299 Consideration will be given to strengthening SO5 locks (a Scheduled Ancient Monument) at Caen Hill near Devizes, and the steam-powered Canals. references to the Kennet and Avon canal in the Canal Pumping Station at Crofton, near Great Bedwyn. Both are as significant to their time pre-submission draft core strategy. period (the early 19 th century) as Stonehenge and Avebury are to their earlier era. Caen Hill and Crofton are both as deserving of protection from unsympathetic development as are Stonehenge and Avebury. In 2009 alone, the Kennet & Avon Canal attracted over 3.4 million visitors into Wiltshire, with a resulting total visitor spend of over £35 million. The current volunteer-driven restorations of the Wilts & Berks and Cotswold Canals are advancing at a significant rate, again providing much potential for the future. It should also be noted that the waterways lie at the very core of urban regeneration schemes proposed for towns such as Swindon and Melksham. Whilst less dramatic than Caen Hill and Crofton, the other waterways across Wiltshire offer a peaceful passage through pleasant rural scenery, a highly beneficial "green corridor" within Wiltshire towns and a useful "green barrier" between neighbouring settlements. Many of the canal's towpaths are already part of the National Cycleways, and more are capable of being similarly upgraded. Wiltshire's waterways are also absolutely key aspects of the attraction, and local economies, of towns such as Bradford-on-Avon and Devizes, and lie at the very heart of the many hundreds of villages they pass through. The waterways' facilities and their potential to play a greater role as a leisure amenity are already plain to see, and deserve recognition within the Core Strategy. Just two examples will suffice to illustrate the potential. Firstly, proposals have recently been put forward by Wiltshire Council to Cross Comment No. Comments Officer Comments Issue Reference By refresh the historic buildings at Devizes Wharf and to enhance the surrounding area as a visitor attraction. These proposals are greatly welcomed and supported by the Kennet & Avon Canal Trust. However, their impact would be greatly increased by their inclusion within an integrated approach to canalside development and visitor provision through the Core Strategy, rather than as a "one off" project for a single location. Secondly, the Kennet & Avon Canal currently forms not only a demarcation between Hilperton and Trowbridge, but also a useful secondary route between them. The towpath also forms a well-used cycle and pedestrian route onwards to Bradford-on-Avon and has the potential to join up with similar links along the River Biss. As such, it meets the objectives outlined in para 5.3.3 of the Consultation Document. This role should be explicitly recognised within the Core Strategy. Attractive living conditions should, we suggest, include easy access to a wider range of sites for informal recreation than just local parks. The waterways already provide for low-key activities such as strolling and dog walking, as well as for angling, cycling, jogging, wildlife watching, canoeing and similar. Additionally, the waterways pass through the heart of the County, they are easily accessible to much of Wiltshire's population. Attractive canal leisure facilities require appealing canalside locations. We therefore urge the Council to recognise, within the Core Strategy, the need for proposals for development close to the canal to be particularly sympathetic to their location, whether in rural and urban surroundings. Isolated rural sites that may have been used in the past for local canal-related industry may now be inappropriate for modern "kit built" warehouse developments that no longer relate to their original function. New housing developments, if sited close to the canal, should be confined to current urban areas and set back from the waterway. In summary, the Kennet & Avon Canal Trust is extremely disappointed that the Core Strategy has not taken account of the existence of the waterways and their associated infrastructures as a key geographic and historic feature of Wiltshire. In consequence, the Core Strategy does not yet include proposals to make good use of these valuable - and, in many cases unique - amenities. The Trust would be very pleased to work with County members and officers to rectify this major omission. Paragraph 1.1 The document refers to building on the ‘Wiltshire 2026' document, however, it also makes reference to the pending abolition of the Regional Spatial Strategies (‘RSSs'), which identified both levels of housing and employment growth. The document advises that the number of proposed jobs and homes is lower than the RSS targets and we are concerned that at this point in time regard should be had to these figures as it forms part of the planning framework and was material in the determination of a recent planning appeal at Brynards Hill in Wootton Bassett. In addition, the Core Strategy assumes that the RSS no longer forms part of the development plan, but that is not correct. Whilst the Government has announced its intention to revoke the RSS's in the current Localism Bill, this has not occurred to date. The Noted. At the recent SWCS Examination In Core Strategy does not provide the RSS housing numbers but instead proposes a reduced public the inspector confirmed that the SWRSS amount of housing; where lower housing figures than those in the RSS are proposed need they had little weight as there was no intention to to be fully justified, and should address a range of economic conditions and housing numbers. finalise the document and therefore the Council Paragraph 1.3 In order to address the objective to minimise the need to travel, new houses as the responsible body have undertaken further 2300 should be provided in locations close to key employment centres. In this respect it should be research to determine the correct level of housing Chapter 1. Q22 acknowledged that Swindon although located within a neighbouring authority, is still an and employment. It should be noted that important location for employment for north Wiltshire, particularly on its eastern fringe, which supporting evidence base for example the retail abuts the administrative area of Swindon. On this point it should be remember that the proper study does take into account the cumulative planning of an area requires cooperation and joint working between planning authorities as the impact of settlements outside of Wiltshire such as impact of a planning document and its policies do not stop at the administrative boundary. This Swindon, Southampton, Bath etc. point is reinforced in the recently published draft National Planning Policy Framework. Paragraph 1.4 The first bullet point refers to ensuring a sustainable pattern of development in order to minimise the need to travel and maximise the use of sustainable transport. It should be considered that just because the employment location is located within an adjoining authority would add to commuting; particularly as the journey from the eastern fringe of north Wiltshire to Swindon would be shorter in distance than travelling from this location to one of the larger centres within Wiltshire. Therefore, a sustainable form of development could be a strategic development West of Swindon, which could utilise sustainable transport on the West of Cross Comment No. Comments Officer Comments Issue Reference By Swindon serving the proposed housing development at Tadpole Farm. Paragraph 1.10 In order to provide new homes in the most sustainable location the importance of Swindon should not be under estimated as not only an employment centre but also for the provision of retail and leisure related activities. Particularly, as future development on the eastern fringe of north Wiltshire could utilise sustainable transport in the West of Swindon serving the proposed housing development at Tadpole Farm. Paragraph 1.20 It is noted that the overarching aim of the Core Strategy is to deliver sustainable development. This approach should include developing locations, including on the eastern fringe of north Wiltshire, as this would result in a sustainable form of development, as due to the relative short distance residents would be able to access employment, shopping and leisure facilities in Swindon by sustainable transport. The fact that these facilities are in Swindon, over an administrative boundary does result in the development being unsustainable, particularly if to visit a centre in Wiltshire that would offer similar facilities would require a longer journey. It would be wrong to discount a development just because it was on the other side of an administrative boundary.

Paragraph 2.7 In respect of the reference to high levels of out commuting; the Core Strategy advises that the area suffers from high levels of out-commuting and expenditure loss to the surrounding urban centres (including Swindon). However, the draft Topic Paper 17 (Housing Requirement Technical Paper), states in paragraph 5.19 that the flows out of the County are Wiltshire does experience high levels of net out- relatively small compared to the employment centres of Chippenham, Trowbridge and commuting. It also experiences high levels of Salisbury. This paper goes on to advise that reducing out commuting to zero is very ambitious. flows to the principal settlements. This is not We would comment that the reason for out commuting is for a variety of reasons including that contradictory, but rather shows that where a person may choose to live and work in different locations as the relative settlements offer employment opportunities are available locally different characteristics and respond to different requirements. It is considered that the Core these will attract local workers. However, due to Strategy will have very little success in influencing these decisions. Paragraph 2.11 In respect the imbalance of jobs to workers in Wiltshire a of the reference to the net out commuting to surrounding employment centres beyond the significant proportion have to commute out of the County boundary. It should be noted that in the draft Topic Paper 17 (Housing Requirement area.The Core Strategy seeks to balance Technical Paper), in paragraph 5.19 advises that the flows out of the District are relatively small employment and workers within the community compared to the employment centres of Chippenham, Trowbridge and Salisbury. We would areas, and housing market areas. This will comment that the reason for out commuting is for a variety of reasons including that a person increase the sustainability of localities.The may choose to live and work in different locations as the relative settlements offer different housing requirement was developed using both characteristics and respond to different requirements. In addition, commuting across the County an economic and demographic approach and could result in less sustainable development when compared to a relatively short journey seeks to balance these. Indeed, Topic Paper 18 2301 across the administrative boundary from the eastern fringe of north Wiltshire to Swindon. demonstrates that the housing requirement will Chapter 2. Q22 Paragraph 2.12 It is accepted that due to a number of factors, including its environment support economic growth.Further work will be Wiltshire is a desirable place to live and in certain locations where it adjoins larger employment undertaken to ensure that the plan includes centres outside its boundary (e.g. Swindon), which are in easy reach will experience out sufficient flexibility and contingency to provide for commuting. This exerts a demand for more houses, which is further exacerbated by the by the changes in the future, including economic growth of the population and small households, which combined places a further demand for changes.Delivery in addition to the strategic sites new houses. In order to cater for this demand it is necessary to ensure that sufficient additional will be delivered through the neighbourhood houses are provided. The number of new houses should be in step with the County's proposed planning process and if required through a economic growth, which seeks to provide new jobs in the right location and to stem out subsequent site allocations DPD. These sites will commuting. However, it is noted that in the Topic Paper 17 (Housing Requirement Technical be identified from those within the SHLAA, which Paper), the Council have based their housing projections on a ‘population led' approach as clearly demonstrates that there are sufficient sites opposed for example an ‘economic led' approach, which would require additional new houses. to meet the required provision for 15 There is a concern that the current approach may not be in step with future economic years.Wiltshire Council and Swindon Borough conditions and levels of housing demand; particularly as over the plan period there is a real have worked collaboratively to ensure that the likelihood that the economic conditions will improve and we will experience a period of requirements of Swindon are delivered in sustained growth. This will exert additional pressure for new housing, which if it is not provided sustainable, appropriate locations. could restrict economic growth and force more commuting, which would be contrary to the Core Strategy's sustainable objectives. The Core Strategy is proposed to last for a period of 15 years but various events can have a detrimental effect on the delivery of housing over the plan period, Cross Comment No. Comments Officer Comments Issue Reference By therefore, it is necessary to develop a ‘contingency' plan in order to address events that may affect the delivery strategy. The contingency plan should consider how the delivery of housing will be monitored; develop trigger(s) as to when to move to the contingency plan; and agree an approach on how the contingency will be delivered. Events that could trigger the need for the contingency plan could include amongst other things: Critical / essential infrastructure is not provided ahead of strategic sites; The delivery of strategic sites are delayed and new housing does not come forward as required; Delivery of housing does not come forward at the required rate either because completions fail to keep up with the intended trajectory or a greater number of houses are required as compared to the plan projection. In order to address any shortfall in delivery the draft Topic Paper 17 (Housing Requirement Technical Paper), in paragraph 11.1 advises that if sufficient land supply cannot be demonstrated then planning applications should be determined favourably; although this does not automatically result in proposals being approved. The approach of leaving potential shortfalls in housing deliver to the availability of potential windfall sites is considered entirely inappropriate and not consistent with PPS3 and the principles of the plan led system, and will result in ad hoc development. To address the above situations an appropriate contingency plan should be promoted in order fill in the gaps in required housing. In order to address this potential concerns with regards the proposed allocations being ineffective or failing to deliver the required number of housing numbers, we consider that in order to address any shortfall in housing deliver, alternative suitable locational(s) capable of delivering sufficient homes should be identified. This should include location(s) that have the potential to provide small to medium sized sites that can deliver new residential dwellings and have the ability to be implemented independently. It is noted that the current version of the Core Strategy no longer includes a specific allocation for West of Swindon. However, Swindon is the nearest largest town in the area, and is located immediately to the east of north Wiltshire. It is an important regional centre and there is a need to provide more jobs and housing and to improve the services and facilities available. It is considered that an urban extension to the West of Swindon (including the site at Pry Farm) would result in a sustainable form of development. Therefore, as this represents a sustainable location and in order to account for any potential shortfall in housing provided over the plan period it is recommended that a reserve provision of up to 3,000 homes be provided to the West of Swindon; which will require joint working between the two authorities.' With the future revocation of the RSSs there is a requirement for a better partnership between authorities in order to achieve the right outcome for Wiltshire settlements and the wider area. However, this does not appear to be reflected in the Core Strategy, as it does not make reference to the sustainability of Swindon, which is a regional centre to act as the focus for development. In addition, of particular concern is that in the draft Topic Paper 3 (Settlement Strategy), paragraph 4.42 highlights the approach taken in neighbouring authorities but fails to make reference to Swindon, despite its close proximity and influence. Paragraph 2.15 It is recognised that the County experiences a degree of commuting, however, as acknowledged draft Topic Paper 17 (Housing Requirement Technical Paper), in paragraph 5.19 that the flows out of the County are relatively small compared to those to the employment centres of Chippenham, Trowbridge and Salisbury. Therefore, the impact of commuting out of the County is not considered to have as great an impact on sustainability as commuting within the County. In order to reduce commuting in general it is important to enable to work locally so new employment sites need to be provided in the most sustainable locations and close to existing / proposed areas of housing in order to reduce travel. In providing new employment opportunities it is important to ensure that the right type of development (in terms of types of jobs) are provided in the right location (in terms of existing and proposed housing levels) in order to ensure economic growth. However, in reading the Core Strategy we are concerned that the approach adopted by the Council seeks to limit the number of new jobs and homes to prevent / restrict out commuting. There is a danger that when the economic conditions improve and there is a demand for the new jobs, these would be artificially restricted by this approach as there would not be sufficient new homes to keep in step with demand. This could put a cap on economic growth, contrary to objective of the plan; or alternatively the restricted supply of new Cross Comment No. Comments Officer Comments Issue Reference By homes would increase housing shortage and result in greater levels of commuting as the housing is not available in the right location, contrary to the plans sustainable development objective. Paragraph 2.17 The provision of sufficient number of homes (including affordable houses), in the right location over the plan period is necessary in order to ensure sustainable development. The level of new dwellings provided should be in-step with the County's projected economic growth, however, we are concerned that the approach to prevent out commuting could have a detrimental effect on economic growth as the required number of new homesmay not be provided to complement the new jobs or that there is insufficient new homes, which results in additional commuting. The objective of any Local Development Framework is not just about allocating sufficient land to provide new homes but importantly, it also about ensuring deliverability. This is largely dependent on allocating sites where there is a real prospect (available, suitable and achievable), of delivery within the anticipated timescale. It also requires a mechanism to ensure that sufficient sites are brought forward at the right time to enable delivery. PPS3 requires that local planning authorities maintain a flexible and responsive supply of housing land that reflects the ‘Plan, Monitor, Manage' approach. This supports the need for a clear policy approach that indicates the timing of potential housing sites in relation to the housing trajectory and the 5 year supply of land. The recently published Draft National Planning Policy Framework reinforces the need for plans to identify and maintained a rolling supply of deliverable sites sufficient to provide 5 years worth of housing against their housing requirements. Furthermore, in order to facilitate economic growth it goes on to state that the supply should include an additional allowance of at least 20% to ensure choice and competition in the market for land. In addition, to the 5 year supply of deliverable land, PPS3 also requires a further supply of specific, developable sites for years 6-10 and where possible, years 11-15. In the event that the market does not deliver sufficient homes to meet requirements, sites will be brought forward from future year's allocations (including reserve sites) to ensure housing delivery targets are met. To ensure that a continuous 5 year supply through the Spatial Framework there is a need to either identify a contingency of ‘reserve' housing sites or the criteria by which reserve sites will be assessed, in order to compensate for any of the preferred allocations that may not come forward or do not deliver the target number of dwellings in the required timeframe. The contingency plan should consider how the delivery of housing will be monitored; develop trigger(s) as to when to move to the contingency plan; and agree an approach on how the contingency will be delivered. Events that could trigger the need for the contingency plan could include amongst other things: Critical / essential infrastructure is not provided ahead of strategic sites; The delivery of strategic sites are delayed and new housing does not come forward as required; Delivery of housing does not come forward at the required rate either because completions fail to keep up with the intended trajectory or a greater number of houses are required as compared to the plan projection. In order to address any shortfall in delivery the draft Topic Paper 17 (Housing Requirement Technical Paper), in paragraph 11.1 advises that if sufficient land supply cannot be demonstrated then planning applications should be determined favourably; although this does not automatically result in proposals being approved. The approach of leaving potential shortfalls in housing deliver to the availability of potential windfall sites is considered entirely inappropriate and not consistent with PPS3 and the principles of the plan led system, and will result in ad hoc development. To address the above situations an appropriate contingency plan should be promoted in order fill in the gaps in required housing. In order to address this potential concerns with regards the proposed allocations being ineffective or failing to deliver the required number of housing numbers, we consider that in order to address any shortfall in housing deliver, alternative suitable locational(s) capable of delivering sufficient homes should be identified. This should include location(s) that have the potential to provide small to medium sized sites that can deliver new residential dwellings and have the ability to be implemented independently. It is noted that the current version of the Core Strategy no longer includes a specific allocation for West of Swindon. However, Swindon is the nearest largest town in the area, and is located immediately to the east of north Wiltshire. It is an important regional centre and there is a need to provide more jobs and housing and to improve the services and facilities available. It is considered that Cross Comment No. Comments Officer Comments Issue Reference By an urban extension to the West of Swindon (including the site at Pry Farm) would result in a sustainable form of development. Therefore, as this represents a sustainable location and in order to account for any potential shortfall in housing provided over the plan period it is recommended that a reserve provision of up to 3,000 homes be provided to the West of Swindon; which will require joint working between the two authorities. With the future revocation of the RSSs requires better partnership between authorities in order to achieve the right outcome for Wiltshire settlements and the wider area. However, this does not appear to be reflect in the Core Strategy, as it does not make reference the sustainability of Swindon, which a significant centre to act as the focus for development. In addition, of particular concern is that in the draft Topic Paper 3 (Settlement Strategy), in paragraph 4.42 highlights the approach taken in neighbouring authorities but fails to make reference to Swindon, despite its close proximity and influence.

Paragraph 3.4 In respect of the ‘key outcomes' and 7th bullet of addressing out commuting, we are concerned how the Core Strategy cannot addressed this issue without having a detrimental effect on economic growth and / or the provision of new homes. In particular, the approach to prevent out commuting could have a detrimental effect on economic growth as the required number of new homes may not be provided to complement the new jobs, which could restrict growth or that insufficient new homes will be provided resulting in a disparity between demand and supply, and will result in availability and affordability issues. This will have the effect that it Important point and at the heart of the strategy is will require additional commuting as employees cannot secure housing close to their workplace. the delivery of jobs and homes in tandem. This Paragraph 3.6 It is noted that the strategic objective to provide everyone with access to a will be achieved through the master planning of decent affordable home only looks to make provision for around 37,000 new homes in Wiltshire sites and phasing agreements to ensure growth is 2302 Chapter 3. Q22 up to 2026. This figure is lower that the figure contained within the draft RSS; where lower balanced. We feel that the growth levels are housing figures than those in the RSS are proposed they need to be fully justified in order to ambitious but proportionate to the environmental address a range of economic conditions and housing numbers. As has been detailed in the capacity of Wiltshire and will make significant draft Topic Paper 17 (Housing Requirement Technical Paper) there is a concern that the impacts towards our objectives. proposed ‘population led' approach strategy focuses on the current low level of growth and does not include sufficient flexibility to respond to a different economic climate and higher levels of growth, particularly in the medium to long term. Therefore, the issue of deliverability of the spatial strategy needs to be explored, together with the need to include a contingency plan of reserve strategic allocations; including a small scale extension to the West of Swindon, which was included in ‘Wiltshire 2026' document as part of the proposed housing allocation. Cross Comment No. Comments Officer Comments Issue Reference By Please see attached documents for comments on behalf of Bourne Leisure Ltd in relation to 2317 comments noted Chapter 3. Q22 Paragraph 3.1 and Strategic Objectives 1, 5, 6, 8 and 10.

Paragraph 5.0.10 Period of housing delivery for the Core Strategy starts in 2006, however, we are of the opinion that to start in 2006 is very retrospective and may not be the appropriate starting point. In particular, while the draft Topic Paper 17 (Housing Requirement Technical Paper), in paragraph 9.4 advises that there have been significant completions since 2006, Comments noted. The plan period is deemed 2324 paragraph 6.21 stated that since the economic crash in 2008, dwelling reduced to 1,651 in Question 2 appropriate. 2009/10, despite the availability of sites. This level of completions represented the second lowest level of completions since 1996/7. The inclusion of the house figures prior to 2008 has the effect of skewing the number of completions and instead a later start date should be considered to reflect more accurately current completion rates.

Policy CP42 Agree with the principle of promoting and developing sustainable transport in order to connect the development with existing centres and employment, shops and services. In order to provide sustainable transport will require a financial contribution from qualifying developments, however, these will need to be of a certain quantum in order to provide the required level of funding. In addition, funding from several developments may be needed to be pooled in order to provide the sustainable transport measures. By restricting the amount of housing development, for example to address the issue of out commuting, could severely limit the amount of funding and prevent the sustainable transport measures being delivered. Consideration also needs to be given to locating development in the most sustainable locations in order to ensure that there is a reasonable chance that bus service will be used by residents and that the service will be continued once the financial assistance provided by the legal agreement has ceased. Policy CP43 Agree that developments should be located in the most Core policy 42: Support noted. Transport sustainable locations, however, in applying this approach considerations should also be paid to contributions will be outlined through the the appropriateness of developing sites that will take advantage of employment, shopping and emerging infrastructure LDF and the future CIL service facilities that may be located in adjoining authorities. In this respect the importance of charging schedule. Core Policy 43: The Swindon to the eastern fringe of North Wiltshire cannot be ignored as by reason of its close sustainability of developments will be considered proximity, size, combined with the existing level of employment and service opportunities mean in regard to the surrounding area, not just within it is already a significant centre. In light of the above it would be wrong to exclude the 2344 the Wiltshire administrative boundary. Core Policy SO8 importance of Swindon in considering the proper planning of the area just because it is located 44:Contributions from new developments will be within a different administrative area, particularly where an urban extension adjacent to the outlined in the emerging Infrastructure LDF and west of Swindon would result in a sustainable pattern development and can contribute to a the future CIL charging schedule. Core Policy 46: utilise sustainable transport measures. Policy CP44 Agree that appropriate financial The demand management policy is under contributions will be required to offset any adverse impacts on the transport network, however, consideration in the coming months prior to the it in order to ensure the construction and operation of the transport network it will be appropriate next draft version of the core strategy. to pool funding from a number of developments. This funding should be provided at a prorate basis dependent on the relative impact of the proposed development on the highway network. Policy CP46 In terms of the proposed requirement for residential car parking spaces, we are concerned about the preference to use unallocated communal car parking. Our concern in respect of this type of car parking is that as it is not attributed to and separated from an individual property, which would result in potential crime and community safety issues, as the spaces will not be sufficiently overlooked. In order to address this individual houses / flats should have a dedicated parking space within their plot, and overlooked by their windows. With regards the provision of visitor spaces these areas should be well designed and located, to ensure that they are overlooked by multiple properties and close to the road (not in rear courtyards) in order that at night these spaces are ‘search lighted’ by car headlights as they go through the development. Cross Comment No. Comments Officer Comments Issue Reference By Noted - National policy, particularly in the form of PPS3 & PPS4, states that through the Core Strategy the council should promote greater levels of development at settlements with the facilities and infrastructure to support that There is a concern that the proposed ‘population led' approach focuses on the current low level development and provide the best opportunity to of growth and does not include sufficient flexibility to respond to a different economic climate offer jobs and homes in the most sustainable and higher levels of growth, particularly in the medium to long term. Therefore, the issue of manner. The designation of the principal deliverability of the Core Strategy needs to include flexibility to consider high rates of jobs and settlements allows the best opportunity for 2347 housing, together with the need to include a contingency plan including a small scale extension Wiltshire to fulfil its requirement for jobs and Question 2 to the West of Swindon. Furthermore, we support the proposed urban extension at Tadpole homes within environmental limits. Topic paper Farm (within Swindon), which could combine with a potential urban extension at West of 17 paper sets out the progress made in Swindon, and represents a sustainable form of development linking both with the established determining an appropriate requirement and communities and communities created by the urban extension(s). distribution of housing for Wiltshire from 2006 to 2026 to inform the draft Wiltshire Core Strategy. This process considers the strategic objectives for the county as well as taking into account local factors and aspirations for growth identified through community consultation. Whilst the objective of providing employment and housing to complement each other is laudable, it is unrealistic as people have a free choice of where they work and live. The adverse consequence of such a policy on Bradford on Avon in particular without a wider assessment of the traffic implications of increased commuting would be severe. Bradford on Avon sits between the Trowbridge area and the magnet of employment of the Bath, Bristol and M4 and M5 corridors. The building of a large number of houses in the Trowbridge area can only exacerbate the already serious traffic problems. At rush hour traffic is at, or near, saturation. The topography of the town makes walking hazardous, particularly for the aged and disabled; there Noted. Transport models for the main is also a pollution problem caused by traffic fumes in narrow streets and steep hills. These settlements such as Trowbridge will be prepared 2357 conditions are well known to the authorities and the latest initiative to mitigate the effects of to inform the core strategy and should the need Chapter 1. Q22 traffic in the area is Priority for People, particularly the Historic Core Zone. As yet such for strategic roads to be built this evidence will initiatives are unproven. I therefore object to the principle that employment and housing can be highlight the need. achieved on a local basis and without consideration of the wider infrastructure needs across community areas and including the relationship with B&NES and the wider area. In this context it is worth mentioning that previous planning documents have included a provisional and reserved route for a relief road around Bradford on Avon. Whilst the provision of such a road may be problematical the building of large numbers of houses in the Trowbridge area could make one essential, thus planning should include the reservation of a route for a relief road. Whilst this comment is made against Chapter 1 it is applicable to other related Sections. Cross Comment No. Comments Officer Comments Issue Reference By Core Policy 43 – Transport and Development Core Policy 26 – Sustainable Construction and Low Carbon Energy Core Policy 28 – Providing Affordable homes Core Policy 3 – Lifetime Homes standards 2.31 These policies are dealt with together as they all have implications for development viability and the principles referred to in proposed Core Policy 3 dealing with infrastructure requirements that is commented on above. 2.32 No objection is raised to the objectives behind these policies. Development, however, is subject to an increasing burden in A viability assessment of all policies is being relation to a wide variety of matters that can frequently affect viability and delivery, particularly undertaken. The information gained in this 2377 in difficult economic circumstances. 2.33 This may mean that priorities have to be set and SO8 exercise will be used to refine the proposed choices made in individual cases if homes are to be provided when and where they are policies, ensuring that they are viable. needed. It is thus important that the viability principles set out in Core Policy 3 are extended to those policies as they affect development in exactly the same way. This could be achieved with appropriate cross referencing between the policies and possibly some additional wording to confirm the linkage. 2.34 As far as Core Policy 28 specifically is concerned no planning purpose is served by the proposed requirement that affordable housing should be delivered in all cases with nil public subsidy. This is a funding issue rather than a land use planning matter. 3: CONCLUSIONS 3.1 The Wiltshire Core Strategy Consultation 2011 seeks to strike key balances between housing and employment provision and also between the specific allocation of strategic sites and the identification of overall housing requirements that are intended to be the subject of specific site allocations in the future. 3.2 As far as the first of these is concerned, there are major problems identified in these representations in terms of attempting to achieve a The overall housing requirement for Devizes and greater degree of self containment for Wiltshire as a whole by attempting to use planning Devizes community area has been established policies to radically change patterns of behaviour at a time when significant flexibility is required through an evaluation of historic rates of in relation to migration and moving to jobs. Notwithstanding these important issues, there is a development, future population and job change, clear and simple land use logic to locating housing and employment in proximity to each other. constraints within the highway network and In this regard there is a strong case for a strategic housing allocation at Devizes to complement concerns about air pollution. It is considered the proposed major new employment site off Horton Road and the site Coate Bridge is ideally appropriate for Devizes and, in scale, is located to meet this objective. 3.3 On the second key matter, the proportion of new housing consistent with other similar sized market towns requirement proposed for the Market Towns in Wiltshire that is deferred for future identification in Wiltshire. The employment site at Horton Road 2378 in site specific terms is very high given the importance of these settlements in achieving the Devizes has been identified to respond to recent large objectives of the Core Strategy. A further strategic site at Devizes would help to address this scale housing development that has come problem having regard to its significant role as a free standing settlement that is relatively forward additional too previous local plan remove from other sources of new housing to support job growth. 3.4 The site at Coate Bridge allocations, restructuring of employment sites can thus fulfil the two objectives of securing development in the right place at the right time. 3.5 within Devizes, to respond to future job growth In the wider context, the government’s March 2011 statement on Planning for Growth and the and to provide an opportunity for more people to emerging National Planning Policy Framework (NPPF) make it clear that the emphasis in both live and work in Devizes ie respond to an existing forward planning and development management should be on planning positively for new situation. An additional site at Coate Bridge is not development. At the same time it is important that local communities are engaged fully in the required during this plan period. process of planning for new development and that any benefits arising from such development are directed wherever possible to the communities that host them. 3.6 This balance can also be successfully achieved with a strategic housing allocation at Coate Bridge with full community engagement as an essential component of all stages of the planning process. The attached report contains details of the site. Cross Comment No. Comments Officer Comments Issue Reference By 1. Transportation 1.1 In general we support the approach of the revised Wiltshire Core Strategy Consultation Document. In particular, we support the increased emphasis on self- containment, sustainable transport, and development which reduces the need to travel. 1.2 We support Strategic Objective 8 and the associated key outcomes, and Core Policies 42, 43 and 45. 1.3 In Core Policy 44 we would like to see some recognition of the need to consider cumulative and cross-boundary impacts on the network. 1.4 This is because Dorset has particular concerns about the A35 corridor. We note the intention to concentrate development on this route, especially at Trowbridge and Warminster. This could potentially cause detrimental cumulative The support for the strategy is noted. The 2382 impacts on local communities and villages on the route in Dorset. Although traffic on the A35 in concerns with regard to the A350 are also noted SO8 Dorset is currently below theoretical capacity, there are a number of pinch points that will and will be addressed through Core Policy 43. constrain increased traffic flows. Nevertheless we recognise and welcome the emphasis on and aspiration toward self-containment in the proposals and hope to manage impacts through an appropriate route management strategy. We therefore look forward to working with Wiltshire to achieve this. 1.5 Finally, we request that policy TR2 of the Salisbury District Local Plan which protects land reserved for the Shaftesbury Bypass be carried forward in the new Wiltshire Core Strategy. Although it is unlikely that the bypass will be built in the current LTP period (211-226), it remains an aspiration at this time. The support and concerns are noted and will be As Highways Authority, Hampshire County Council would encourage use of the advisory freight addressed through policies within the South network and the strategic road network for non-local journeys and would like to comment on the 2386 Wiltshire Core Strategy with regard to the New SO8 detail of any emerging cross boundary issues at the appropriate time. Any impact on the New Forest and the package of transport policies Forest National Park from additional traffic would be our main concern at this time . within the Wiltshire Core Strategy.

Core Policy 46 As Highways Authority, the County Council notes there is no mention of the Whilst electric charging points are not specifically possible introduction of electric vehicle charging points in the document. Hampshire have been mentioned, Wiltshire has submitted a bid to 2388 working in partnership with others to develop a network of charging points across the County, SO8 government for funding to develop these within and would support the development of charging points in neighbouring authorities to provide a the Local Transport Plan. more comprehensive & wider network.

Core Policy 47 As Highways Authority, Hampshire County Council is supportive of the policy to encourage HGV traffic to use those roads where a minimum of community and environmental impact will occur. This comment has particular relevance in respect to proposed development in The support for the strategy is noted. Any the Salisbury area. In previous years HGV traffic from the A338 has through-routed across New additional traffic generated through development 2389 Forest National Park roads (B38/79/78) as a short cut to the strategic road network. This has SO8 in the Salisbury area will be mitigated through the brought about a HGV restriction which covers the northern New Forest and Downton and Red development of transport strategies. Lynch in Wiltshire. HCC would be concerned about any additional HGV traffic generated by developments in the Salisbury area contravening the HGV restriction or trying to find even less suitable routes across the forest. Cross Comment No. Comments Officer Comments Issue Reference By 3.1 Chapter 2 of the consultation document is entitled, ‘What is Wiltshire like now?’ This sets out the profile of Wiltshire as well as proposed issues and challenges for the Core Strategy to tackle. We broadly support this section, but make the following observations: Population 3.2 The ‘Population’ section of the consultation document sets out the changes to the demographic profile of Wiltshire over the plan period. It states that over this timeframe there will be an 89.4% increase in age groups over 85. This group has the highest level of care needs. This in addition to a doubling the number of disabled people by 2026. 3.3 The most up-to-date Department of Community and Local Government (DCLG) projections provide further detail. This shows that between 2008 and 2033 (a slightly different timescale to the plan period, but still relevant) 78% of household growth in Wiltshire will come from the over 65 age group. 3.4 This highlights the Further work is being undertaken within the significant growth of these age groups and the need to plan appropriately. We consider that this Strategic Housing Market Assessment to identify means providing a significant amount of older person care and accommodation. Whilst many of the accommodation needs of the elderly. This 2392 Chapter 2. Q22 those in this age group will choose to remain in their own homes, many will not and the Council evidence will be used to develop policies to needs to ensure that choice is provided for them 3.5 As stated, many older people will choose ensure that a sufficient supply of appropriate to remain in their homes for longer, often under-occupying family homes. Unless the Council accommodation is delivered plans appropriately this will limit the availability of family homes, and will result in increasing competition for a restricted number of dwellings. This will have an upward effect on house prices, and will have a detrimental impact on housing affordability and the ability of families to purchase in the area. Housing 3.6 The Council fully acknowledges that the affordability of housing is an issue. However, given that the average house costs 7.5 times the average wage and the Council housing register contains 10,000 individuals, we consider that it should be classified as a ‘significant’ issue worthy of urgent attention. Demographic Change 3.7 We strongly support the inclusion of ‘meeting the needs of the ageing population including extra care housing’ as a key challenge. Support welcomed. The number of Strategic objectives will be rationalised in the next version. Important point and at the heart of the strategy is 4.1 Chapter 3 of the consultation document sets out a ‘Spatial Vision for Wiltshire’. We are the delivery of jobs and homes in tandem. This broadly supportive of this section, but consider that changes to Strategic Objective 3 are will be achieved through the master planning of 2393 necessary given the scale of affordable housing need and the rapidly ageing population. We Chapter 3. Q22 sites and phasing agreements to ensure growth is would also like to see the Spatial Vision make reference to further provision of affordable balanced. We feel that the growth levels are homes and care and accommodation for older people. ambitious but proportionate to the environmental capacity of Wiltshire and will make significant impacts towards our objectives. Cross Comment No. Comments Officer Comments Issue Reference By Topic paper 17 sets out the progress made in determining an appropriate requirement and distribution of housing for Wiltshire from 2006 to 2026 to inform the draft Wiltshire Core Strategy. This process considers the strategic objectives for the county as well as taking into account local factors and aspirations for growth identified through community consultation. Core Policy 2 states that in addition to strategic sites, non 7.1 We broadly support the Core Strategy, but we consider that some significant changes are strategic allocations will need to be brought needed to ensure that the Core Strategy is sound. We consider that a higher housing forward to deliver the jobs and homes proposed. requirement for Wiltshire is needed to meet sub-regional housing need. We also consider that a Community led neighbourhood plans, or another redistribution of housing allocation away from Corsham and Wootton Bassett Community Area planning mechanism, will identify specific sites to to Calne Town is required to ensure a sustainable pattern of development is promoted. 7.2 The deliver this growth within the plan period.Noted Council will also need to ensure that the Core Strategy covers a 15 year period from the date of comment that the plan period should be changed adoption to be considered sound. We recommend that the Council follows the example of to 2010-2030.Noted comments on the need for numerous other authorities currently preparing their Core Strategies and use the 2010 to 2030 older person care – this is enabled through core timeframe. This will mean finding additional housing land up to 2030. In Calne, the increase in policy 29 – meeting housing needs.Topic paper the housing requirement that we propose and the lack of available sites within the development 2398 17 sets out the progress made in determining an CalneHousing Calne boundary, will mean allocating one or more sites for housing and/or care and accommodation appropriate requirement and distribution of for older people outside of the settlement boundary. At the very least the Core Strategy should housing for Wiltshire from 2006 to 2026 to inform state this in the relevant section in order to direct future planning documents. 7.3 There is also the draft Wiltshire Core Strategy. This process overwhelming evidence for the need for an older person care and accommodation scheme at considers the strategic objectives for the county Calne. The Core Strategy should state that one is required in Calne to direct future planning as well as taking into account local factors and documents and applications. Our client is exploring the possibility of providing general aspirations for growth identified through market/affordable housing and/or an older person care and accommodation scheme on the community consultation. Core Policy 2 states that site. We consider that it is the most sustainable site outside of the settlement boundary, due to in addition to strategic sites, non strategic its close proximity to the town centre. It does not require the provision of a relief road to bring it allocations will need to be brought forward to forward and as such should be the Council’s first preference for a Greenfield release. deliver the jobs and homes proposed. Community led neighbourhood plans, or another planning mechanism, will identify specific sites to deliver this growth within the plan period.Noted comment that the plan period should be changed to 2010- 2030.Noted comments on the need for older person care – this is enabled through core policy 46 – meeting the needs of Wiltshire’s vulnerable and older people. 3.1 Vision National planning policy and other relevant references PPS12 para 4.2 English Heritage comment "Wiltshire's important natural and built environment will have been safeguarded". The Vision currently only refers to safeguarding the natural and built environment. As not all of Wiltshire's historic environment is either natural or built an explicit Agree that heritage is an important issue and the reference should be made to reflect the evident ambition to safeguard Wiltshire's heritage SO's will be reviewed in subsequent versions. assets. In addition to reflect the intended progressive approach to heritage management Also polices will be developed which will seek to perhaps there is a vision of actually improving or enhancing the condition and presentation of deliver the objectives set out. The point that part Wiltshire's historic environment? English Heritage recommended change "Wiltshire's important of Wiltshire success is based on how it looks is 2408 natural, built and historic environment will have been safeguarded and enhanced". 3.4 objective made in the introduction and we totally agree that Chapter 3. Q22 1 - to deliver a thriving economy National planning policy and other relevant references PPS4, this is one of the unique selling points of the PPS5, PPS7. Constructive conservation, EH Valuing Places, EH 2011 Heritage Works - Wiltshire that can be used to attract investment, regeneration. EH, RICS etc English Heritage comment The Core Strategy should acknowledge i.e. the quality of life. This point will be further the contribution the historic environment makes to Wiltshire's economic well being. Associated emphasised and reinforced in subsequent outcomes relating to strategic objective 1 can reflect the following evidence in Topic Paper 10 versions. "...there is evidence that historic buildings that have been part of successful regeneration have increased the residential and commercial value. Wider benefits to the local community include improved image and potential for employment increase". (Topic Paper 10, 5.14) High-quality Cross Comment No. Comments Officer Comments Issue Reference By areas can attract people, increase activity and lead to economic improvement. Additionally, they can give a greater sense of safety and attract social interaction (CABE 2006) (Topic Paper 10, 5.16). PPS4 identifies the role of arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities) in economic development. PPS5 highlights the wider social, cultural, economic and environmental benefits of heritage conservation. PPS7 states that tourism and leisure activities are vital to many rural economies. As well as sustaining many rural businesses, these industries are a significant source of employment and help to support the prosperity of country towns and villages, and sustain historic country houses, local heritage and culture (Topic Paper 10, 5.18). Government figures state that heritage tourism accounts for £4.3 billion in GDP and 113,000 employees in the UK. Including historic green spaces, this figure rises to £7.4 billion and 195,000 employees, making the sector larger than car manufacturing and advertising (Topic Paper 10, 5.20). PPS4 encourages new uses for vacant or derelict buildings, including historic buildings. It also highlights that in areas statutorily designated for their natural or cultural heritage qualities, there will be scope for tourist and leisure related developments. The local authority must recognise this whilst considering the number, form and location of developments in order to ensure the particular qualities or features that justified the designation are conserved (Topic Paper 10, 6.2.9). English Heritage recommended change Include explicit reference to historic environment related economic outcomes as highlighted in the evidence base. 3.8 Footnote 5 National planning policy and other relevant references Natural England guidance on the preparation of Green Infrastructure plans English Heritage comment The network of GI fails to refer to relevant related components of the HE. English Heritage recommended change Add historic landscapes, features and historic parks and gardens. 3.10 English Heritage comment EH support reference to town centre and outdoor market enhancement, regeneration. 3.11 5th bullet point English Heritage comment EH support, "Sustainable transport alternatives will have been implemented in a manner which has reduced the impact of traffic on people's quality of life and Wiltshire's built and natural environment including enhancement of the public realm and street scene". Although we recommend you add an explicit reference to the historic environment as not all of Wiltshire's historic environment is either natural or built. English Heritage recommended change "...Wiltshire's built, natural and historic environment.." 3.12 key outcome 4 English Heritage comment EH support, "Appropriate place-shaping infrastructure, such as leisure and open space, green infrastructure, libraries, public art and cultural facilities, will have been secured". 3.2, 3.9 National planning policy and other relevant references PPS12 para 4.3 English Heritage comment EH support Strategic objective 6: to safeguard and promote a high quality built and historic environment. Vision, flair and commitment to reinforcing those qualities that make Wiltshire distinctive will ensure local places are enhanced and not diminished by change. 3.9 4th bullet point English Heritage comment Superfluous reference to "where appropriate". If necessary why isn't "where appropriate" applied to all other Key Outcomes? English Heritage recommended change Reword 4th bullet point at para 3.9. The sensitive re-use of historical buildings will have taken place. Cross Comment No. Comments Officer Comments Issue Reference By CHIPPENHAM COMMUNITY AREA STRATEGY: Chapter 5.1 outlines the characteristics of Chippenham as: • One f the largest towns in Wiltshire; • Excellent transport links • An attractive location for employers • Significant out-commuting; • Significant shortfall in suitable land for Comments are noted. Comments are noted. The employment growth: a failure to respond to this is likely to result in the loss of local employment; evidence now presented provide best solutions • Significant job growth will help to improve the self containment of the town and therefore to accommodate sustainable development at the Wiltshire; Support is given to the strategy to develop the strategic role of Chippenham (5.1.3) town in light of the emphasis on the delivery of and recognition that in order to ensure employment is accessible to the local population a employment land to develop the strategic 2425 sustainable distribution and choice of employment sites is provided at the town (5.1.8). 5.1.8 employment role of Chippenham and the Site Selection Chippenham recognises that in addition to the regeneration of existing urban areas, job growth should also proposed reduction in the overall number of take place as edge of town sites; balanced delivery of jobs and homes will improve the critical homes to be provided during the plan period. mass of the town. Support is given to a balanced delivery not only as regeneration within the The SA/SEA in still at a draft stage and will be existing town fabric but also at its edge and in conjunction with housing development. reviewed and updated in light of new evidence Representations given to Question 5 also support this strategic approach and put forward the which has emerged. Forest Farm site as a credible site on which a balanced delivery of housing and employment can be brought forward. Chapter 5 National planning policy and other relevant references PPS5/ NPPF Spatial Portrait and specific issues 5.0.5/ Each Community Area Strategy English Heritage comment "Each community area strategy begins with a brief description of the area, followed by a list of specific issues to be addressed in planning for the area. This list focuses on those issues which planning policy can assist in addressing, such as the need to improve self-containment or to ensure appropriate phasing of development". Unfortunately the spatial portraits and the determination of specific issues and the future planning of each settlement does not appear to have responded explicitly to an understanding of the significance of the historic environment and the issues challenges and opportunities it faces. The evidence base should go further than simply setting out a list of designated assets, but also consider local assets, the likelihood for unknown assets, particularly archaeology, to be discovered in the future, and the historic character of landscapes and townscapes. In some cases, it might be necessary to identify heritage assets outside of your local authority area, e.g. where there are likely to be wider setting issues with respect to potential development proposals in your area. You should also determine how your area's character has developed, its capacity for change and identify key issues, such as the condition of the plan area's historic places, spaces and buildings, including streets and the public realm, and opportunities offered by the historic environment. PPS5 Comments noted. The strategy includes a core recognises the positive contribution that heritage assets can make, rather than seeing them as policy which seeks to conserve the historic a constraint. An understanding of what is distinctive about your historic environment will help in environment. Further detail in relation to local 2443 SO6 developing a locally distinctive policy. English Heritage recommended change Set out a distinctiveness will be provided where necessary. strategy for the conservation of the historic environment in each settlement/community area in Other elements will also be considered by response to an understanding of its significance, issues, condition, needs and opportunities. officers. Each Community Area Strategy National planning policy and other relevant references Draft NPPF part 24, 26, 34, 37 PPS5 HE 2, 3.1 English Heritage comment There is an expectation that the characteristics and prospects of the HE are understood and a clear strategy for the environmental enhancement of the area is prepared. The individual settlement/community area statements provide the opportunity to do so. The rather generic Wiltshire wide policy approach (Policy 38) is neither locally distinctive or an adequate response to the above expectations. English Heritage recommends that the results of a quantitative and qualitative assessment are used to provide a spatial portrait of the Plan area that demonstrates an understanding of how the historic environment: contributes to the distinctive character of the various parts of the Plan area; contributes to the local economy and the quality of life of its communities; and needs to be addressed in terms of its future management. English Heritage recommended change Demonstrate an understanding of the significance of the historic environment in each area and highlight the issues, opportunities and challenges facing the conservation, enjoyment and enhancement of those assets. Set out a positive and proactive strategy. Each Community Area Strategy National planning policy and other relevant references PPS5 HE3.1 English Heritage comment "...local development frameworks (LDF) should set out a positive, proactive Cross Comment No. Comments Officer Comments Issue Reference By strategy for the conservation and enjoyment of the historic environment in their area, taking into account the variations in type and distribution of heritage asset, as well as the contribution made by the historic environment by virtue of: i. its influence on the character of the environment and an area's sense of place: ii. its potential to be a catalyst for regeneration in an area, in particular through leisure, tourism and economic development; iii. the stimulus it can provide to inspire new development of imaginative and high quality design iv. the re-use of existing fabric, minimising waste; and v. its mixed and flexible patterns of land use that are likely to be, and remain, sustainable." English Heritage recommended change Each settlement/community statement should apply the expectations of PPS5 policy 3.1 Each Community Area Strategy National planning policy and other relevant references Draft NPPF part 24 English Heritage comment The Plan should identify land which it is genuinely important to protect from development, for instance because of its environmental or historic value" English Heritage recommended change Significant components of the historic environment perhaps including key historic settlement, historic parks and gardens, townscapes, landscapes, individual features, setting, views etc should be appreciated, acknowledged and mapped. This is easier to map in the settlement/community area statements. Each Community Area Strategy National planning policy and other relevant references PPS5 HE3.4 English Heritage comment "At a local level, plans should consider the qualities and local distinctiveness of the historic environment and how these can contribute to the development of the spatial vision in the local development framework core strategy". How have these qualities informed the Vision for the planning of each settlement/community area? English Heritage recommended change Each settlement/community area statement should set out how their HE qualities have informed future planning. Each Community Area Strategy National planning policy and other relevant references PPS5 HE 3.4 English Heritage comment "Plans at a local level are likely to consider investment in and enhancement of historic places, including the public realm, in more detail. They should include consideration of how best to conserve individual, groups or types of heritage assets that are most at risk of loss through neglect, decay or other threats (see also policy HE5)". Topic Paper 10 tends to refer to regional and national heritage at risk statistics. The core strategy evidence base should demonstrate the local picture and what the response will be to it. Have conservations area at risk surveys been undertaken? If so are any at risk? If so why and what can the Core strategy do as a part of a positive and proactive conservation strategy? English Heritage recommended change Demonstrate an understanding of the character and condition of each areas heritage assets to inform an appropriate area specific response in accordance with PPS5. Complete heritage at risk surveys.

Interim SA Report Paragraph 5.7.54 Support. Apply principle throughout. Paragraph 5.7.49 Is there sufficient certainty that the significance of the effected assets and their setting will not be Noted. Further evidence is bought sought on affected? What evidence has been gathered to make this judgement? Paragraph 5.7.56 You landscapes and settings and this will published 2454 SA Q22 recognise further work is required to determine the level of harm likely as a resulted of with the pre-submission draft of the Core associated essential infrastructure. Until this is established a decision on which option is Strategy. suitable cannot be made. GI, pg 150 GI should have a positive (+) effect on the HE Cross Comment No. Comments Officer Comments Issue Reference By Strategic Objective 1 – To deliver a thriving economy which provides a range of job opportunities We support the objective to encourage a buoyant and resilient local economy, while ensuring that sustainable development objectives are met Strategic Objective 2 – to address climate change The Agency is in favour of the steps suggested to act on climate change. We also recognise that alongside business and individuals, we have an important part to play in minimising the causes and managing the risks associated with a changing climate. We are encouraged by one of the key outcomes of this objective being sustainable development resulting in a reduction in the need to travel. Strategic Objective 3 – to provide everyone with access to a decent, affordable home The Agency acknowledges the need for 37,000 homes in Wiltshire by 2026 provided that this level development can be accommodated. We support the efficient use of land and the delivery of new homes in the most sustainable locations, and the provision of the infrastructure necessary to support the number of new homes proposed. Strategic Objective 4 – to help build resilient communities We welcome this objective and are encouraged that the strategy to deliver it will include making communities self sufficient which will in turn reduce the need to travel. Strategic Objective 7 – to enhance the 2455 vitality and viability of town centres The Agency are supportive of the approach to enhance the Support welcomed. Chapter 3. Q22 vitality and viability of town centres where these promote self containment and are concentrated around key public transport nodes. This will assist in minimising the volume of traffic on the SRN. It will be necessary for all development schemes to undertake suitable assessment in line with DfT circular 02/2007, Planning and the Strategic Road Network and the Guidance on Transport Assessments, March 2007. Strategic Objective 8 – to promote sustainable forms of transport We welcome the acknowledgment by the Council to reduce the need to travel and ‘encourage the sustainable, safe and efficient movement of people and goods within and through Wiltshire.’ It is also positive to note the requirement that in order to reduce the need to travel and to encourage the use of sustainable travel alternatives, developers will be required to consider this as part of the planning application process for new developments. Strategic Objective 9 – to ensure the infrastructure is in place to support our communities The Agency’s key concern is that the infrastructure provided to support communities should not prejudice the use of alternative modes of transport to the private car. Developments should follow the principles set out in Manual for Streets 2 and focus on place making in order to promote self containment. Core Policies 42, 43, 44, 45 and 46 The objectives set out in the above policies can be successfully delivered through a well-planned and appropriately located development on land at Whilst this may be the case, the development at Washpool, as shown in the attached submission - see associated Transport Assessment 2460 Washpool is not required to deliver these SO8 attached. [see attached full submission for detail and clarification on this point. This forms the objectives. complete submission that should be taken into account] [appendix A submitted in hard copy only]

2461 Braeman Holding Response PDF Attached Noted Q22

Core Policy 48 – Strategic transport network The Agency welcomes acknowledgement that any highway work in relation to the SRN will be undertaken through appropriate consultation. Any proposed improvement works will need to ensure that they do not have a detrimental impact on The support is noted. Core Policy 44 provides the the safe and the free flow of traffic on the SRN. This will be the Agency’s primary consideration direction that development should mitigate their on any proposals put forward by Wiltshire County or by third parties. Conclusion There is no impact on the road network. In order to establish 2476 SO8 transport or trip detail provided in the document, therefore only generic comments have been this an assessment will be required. The policy provided. All developments will need to be supported by TA and TPs and would be reviewed wording and supporting text will be reviewed to against the requirements of Circular 2/27 and the Guidance on Transport Assessments/ We ensure that this is clear. recommend that all future proposals be assessed in terms of their impact on the SRN and whether they comply with sustainable transport policy objectives and relevant guidance. Cross Comment No. Comments Officer Comments Issue Reference By On the whole, there is a lot to support in the first three parts of the draft Core Strategy. There is a clear explanation of overall approach and strategy and the factors that have informed them. It is also encouraging to see a strong emphasis on economic growth and prosperity, together with the conditions and key challenges that the Council faces. Some of these resonate strongly with our experience, notably: a) The Wiltshire settlement pattern (paragraphs 2.3 - 2.6) b) Cross border relationships (paragraphs 2.7) c) The changing population (paragraphs 2.9 and 2,10) d) Oul commuting and self containment (paragraph 2.11) e) Economic growth (paragraph 2. 15) Important points are made in the draft on these topics which whilst not unique individually, do have a special collective implication for planning in Wiltshire. Our concern that this is then lost or diluted because of the length of the draft's introductory sections and this has consequences both for the precision of the vision for Wiltshire and some of the core policies that follow. This position could be corrected if the first three sections were combined and shortened to provide a much more concise (and effective) background to the plan's core policies. In particular a single list of objectives should be provided which cou ld follow those found under paragraph 3,2. No great adjustment is needed to this list and, as stated above, it is refreshing to see attention given to the need and scope for growth. In our view any list must begin with this as its key objective - it reflects both the Plan for Growth and the draft National Planning Policy Framework (NPPF) which states that 'significant weight should be placed on the need to support economic growth through the planning system' (Draft NPPF, 2011, Para. 13). The introductory section (and the Vision if necessary) would also need to recognise much more fully the opportunities for sustainable growth in a range of locations - not just within or on the actual physical edge of the main towns. The vision al the moment fails to recogn ise the wide variety of conditions and opportunities that Wiltshire presents for novel and sustainable forms of growth and activity - and which may only be delivered in different and specific places. V\lhilsl a focus on main towns and reducing travel needs is understandable, this must be matched by greater encouragement for Support noted for the early chapters. Comments other initiatives that can serve larger parts of the County (helping to make Wiltsh ire more self -- regarding rural business development are noted SO1 & Number of 2479 con tained as well as its individual towns). This concern runs through many of our comments on and these policies are being revised. The Q22 Corsham Issues the draft Core Strategy and its policies. Savills provides town planning advice to Hartham Park comments that refer specifically to Corsham have pic, with respect to land and buildings of the same name. These sit to the north of Corsham and been passed on to the relevant officer. provide a range of employment space and leisure opportunities. Planning permission has also been granted for a rural futures centre and a number of further initiatives are currently being considered which would reflect Hartham Park's condition and location as well as its potentiaL We have examined the draft Core Strategy together with some of the background information that supports it. Encouragingly we find much to support in the document and this is reflected in our comments which are recorded on the attached forms. There are however five key areas where we think the strategy could be improved and these run through our comments. None of these need to disturb the significant amount of work that has gone into the strategy: a) there needs to be more recognition of the scope for development and activity beyond defined settlement limits. The plan starts this dialogue - and includes helpful references in policy and text. Our experience is that it could be a little stronger and more explicit b) the vision for the Corsham Community Area needs to be more ambitious and more clearly defined. Again this does not mean that the town needs to move up the settlement hierarchy, but it does need to reflect the energy and opportunity that the town offers c) a more modern approach to economic development should be taken. At the moment the strategy defines this as B class development. There are clearly many more forms of activity and development that generate employment or which support it. This is particularly relevant in Wiltshire because of its geography, its history and the conditions it faces. d) as stated above, there are straightforward mechanisms to improve the plan and many of these come from the document itself. The strategy's policy for MoD sites, for example, provides a useful model which could be extended to other clusters of existing buildings or estates that might lie beyond settlement limites (and could strengthen strategy). e) at the same time, there are some places where the plan's policies could be shortened and simplified to make them more effective and to introduce some important flexibility. Cross Comment No. Comments Officer Comments Issue Reference By These three introductory sections provide useful background to the strategy and the objectives that sit at the heart of it. The strong and primary emphasis on the need for sustainable economic growth reflects the national plan for growth and should mean that Wiltshire is well placed to capture the benefits of its position and the assets and resources it offers. It should also help the County to respond to the challenges it faces. The key messages from this analysis do, however, become a little lost in the first 20 pages of the draft strategy. To provide a proper focus, a single list of objectives in a single brief introductory section could be provided to explain why the plan then takes the shape it does. This could and should follow the list under paragraph 3.2 to emphasise the scope and need for growth as its key objective. This will ensure that the core strategy follows the draft National Planning Policy Framework (NPPF) which states that 'significant weight should be placed on the need to support economic growth through the planning system' (Draft NPPF, 2011, Para. 13). Savills provides town planning The Council will ensure that the Core Strategy is advice to Spring Park (Corsham) Limited, with respect to land and buldings of the same name. compliant with the NPPF and the new Localism Spring Park sits on the western edge of Corsham and a series of planning permissions and Bill as and when these documents develop. approvals (outline and reserved matters) allow the development of a mixed use business park. Employment sites and the approach to economic 2485 Development at the site is now underway. We have examined the draft Core Strategy together CP1 & SO2 development is being developed in line with NPPF Q22 with the -economy· background information that supports it. As we say in our comments, there advice in PPS4 regarding protection and is much to support in the document and the strategy should provide a solid platform for extension to these sites. The comments regarding development management. There are however three key areas where the strategy could help settlement boundaries have been passed to the to attract. capture or accelerate development (rather than stand in its way or potentially confuse relevant officer promoters). None of these need to disturb the significant amount of work that has gone into the strategy: a) The first is the approach to settlement limits. Although this may not be what the Strategy proposes, settlement limits should not present a rigid brake on growth beyond them. Some flexibility is implied at the moment, but given the significance of these limits, further clarity needs to be introduced. b) The second is the insertion of a list of key commitments and sites as part of, or in support of, a single principal policy on economic development. Sites can be easily identified from the work already carried out by the Council and Spring Park should feature as one of the most important in North Wiltshire. c) The third is the approach the plan takes to economic development. This needs to extend beyond a narrow definition (of B class uses) to incorporate more activities (and the infrastructure that supports them). It also needs to recognise the dividend of early delivery - especially in current conditions. In examining the approach taken by Wiltshire Council, we have had particular regard to national policy guidance in respect of the intended role of Core Strategies and the tests that should be applied to ensure that emerging DPD's are ‘sound'. This guidance is principally to be found in PPS12: Local Spatial Planning. Guidance set out in PPS12 (paragraph's 4.36 - 4.51, 5.52 and the boxed text refer in particular) and LDF Soundness Guidance from PINS dated, August 2009, makes clear that to be sound a Core Strategy should be: 1. Justified: PPS12 provides that to be ‘justified' a Core Strategy needs to be: • Founded on a robust and credible evidence base; and • The most appropriate strategy when considered against reasonable alternatives www.wyg.com creative minds safe hands The robustness and credibility of the Core Strategy is in part being tested through this consultation process and we generally conclude that the proposals set out in the plan are justified. However in a small number of instances we believe Noted. This will be looked into however the 2515 Chapter 1. Q22 that the plan is unsound and requires amendment. 2. Effective: The guidance set out in PPS12 council believe the core strategy to be sound. makes clear that Core Strategies should be effective. This means: • Deliverable • Sound infrastructure delivery planning • Having no regulatory or national planning barriers to delivery • Delivery partners who are signed up to it • Coherence with the strategies of neighbouring authorities • Flexible • Able to be monitored In preparing the submitted representations, we have focused on the issues of delivery and flexibility - key requirements in testing the effectiveness of the Core Strategy. We have concluded that in a small number of areas the plan is unsound and requires amendment. 3. Consistent with National Policy: We have concluded that whilst the Core Strategy is generally consistent with national planning policy guidance, in a small number of instances, it is not consistent with this guidance as a consequence is at present unsound. Cross Comment No. Comments Officer Comments Issue Reference By

The National Planning Policy Framework, which is likely to be in force by the time the Core Strategy is examined and adopted, is likely to contain a requirement for Local Planning Authorities' rolling 5 year housing land supply to contain an additional allowance of at least 20% The Council will ensure that the Core Strategy is to ensure sufficient choice and competition. This required increase in available housing land will 2548 compliant with the NPPF and the new Localism NPPF Q22 result in a need for Wiltshire Council to increase the identified housing requirement for the Bill as and when these documents develop. Bradford on Avon Community Area. The Holt Road site represents the most appropriate location within Bradford on Avon to accommodate this additional strategic growth requirement within this Community Area.

TOURISM There is a lack of a topic paper for Tourism. Though it is covered to an extent by a number of topic papers including Green Infrastructure and Built and Historic Environment the lack of a pull together makes it difficult to see what the overall thinking is. The saved section on Tourism from North Wiltshire reads as follows: 13. TOURISM TOPIC AREA POLICIES TM1 GENERAL POLICY FOR TOURISM Proposals for new tourist accommodation will be expected to be located in, or adjacent to, existing towns and villages. Proposals for tourist development within the countryside that improves or extends the range of tourist facilities, including tourist accommodation will be permitted, provided that: i) It would result in the conversion of a suitable rural building; or ii) Forms part of a farm diversification scheme; or iii) Is an extension to existing facilities, of a scale appropriate to its location. Proposals for touring sites for caravans and/or tents will only be permitted where there is a proven need for this type of development. 13.1 The tourism industry is important to the economic success of the District, safeguarding existing and generating new jobs and contributing towards a living countryside. The development of tourism must, however, be sensitive to the environment in which it lies and not reduce the attractiveness of the countryside or negatively affect the amenity of local residents. 13.2 The definition of tourism for the purposes of this Plan is that used by the Tourism Society: "The temporary short term movement of people to destinations outside the places where they normally live and work and the activities during their stay at these destinations." Development proposals that do not accord with this definition of tourism will not be regarded as tourism developments. TM2 WILTS AND BERKS / THAMES AND SEVERN CANALS Restoration of the Wilts and Berks, including the North Wilts Branch, and Thames and Severn Canals along Comment noted. Tourism is an important the routes as defined on the proposals map, will be supported in principle by protecting the 2567 economic sector for Wiltshire and will be SO1 alignment by: i) Not permitting development likely to destroy the canal alignment or its considered in more detail within the next draft. associated structures; ii) Seeking an alternative alignment where development that cannot be provided elsewhere threatens the canal or its associated structures; iii) Ensuring that where the canal is affected by development, the alignment is protected or an alternative alignment is provided and the canal is restored as part of that development process. 13.3 Any proposal affecting the original route of either the Wilts and Berks or Thames and Severn canals will need to be given careful consideration to allow for the preservation of the canal as an amenity and recreational feature. The canal network within the District has the potential to achieve greater accessibility to the countryside from the District's residents and visitors. The use of disused towpaths along stretches of disused and restored canal will be encouraged. TM3 SWINDON AND CRICKLADE RAILWAY LINE It is proposed to restore, for leisure purposes, the route of the former railway line from Tadpole Lane, Swindon to Cricklade, subject to not causing demonstrable harm to any areas of nature conservation interest along its route. 13.4 The route of the former Swindon and Cricklade railway line from the south of Cricklade extends into Swindon Borough to link with Mouldon Hill Country Park. In the long-term, there is the possibility of considering extending any restored railway line route around the north side of Mouldon Hill, within Swindon Borough, and across the River Ray to Moredon Bridge, within North Wiltshire. TM4 THE THAMES PATH NATIONAL TRAIL In connection with the establishment and enhancement of the proposed Thames long distance path, development will not be permitted where proposals are likely to result in a significant adverse effect on the amenities and open landscape along the river and footpath route. 13.5 The Secretary of State for the Environment approved, in September 1989, the proposals of the Countryside Cross Comment No. Comments Officer Comments Issue Reference By Commission for a Thames long distance footpath, submitted under Section 51 of the National Parks and Access to the Countryside Act 1949. The route mainly follows existing rights of way, but in certain areas, new rights of way will need to be created to complete the route. The riverbanks and adjoining open areas are important in creating a green living corridor of nature conservation and landscape value. Such measures as tree planting and water habitats, involving the creation of bays and backwaters in certain suitable locations to create still water areas for plants and nesting will be encouraged. The other former District Councils have saved policies covering tourism which are not reflected in a pulled together form due to the lack of a document on Tourism the introduction to the North Wiltshire policy is quite equally applicable to the County considering its rich past. We would expect the policy TM3 to be reflected as above in the Core Strategy. For information the Swindon and Cricklade Railway is about to start extending into the park at Mouldon Hill. Most of the work is funded and part of the development will see the cutting towards the Moredon Bridge site started.

6.8 SO8 to promote sustainable transport Core Policy 42 to 45 and their supporting text set goals which are in line with current thinking in that they aim to encourage the use of public transport rather than the car. However from paragraph 6.8.14 onwards it does not show that necessary enthusiasm and drive to support the aspirations. If we look at Core Policy 45 bullet point 2 enhanced public transport services and facilities we do not see this reflected adequately in the policies that follow on. Core Policy 46 Demand management is basically about using parking charges to discourage car use. This policy should contain a carrot as well as a stick namely the first bullet point should be something along the lines of • sustainable public transport, both bus and rail will be encouraged to reduce the need for public car parking. Core Policy 47 Movement of goods this seems to have its bullet points not necessarily in the correct order to achieve the aims set. We would suggest that the last bullet point is moved to become the first and reworded as below. • the provision of intermodal and other rail freight terminals in suitable areas will be supported and land required for realistic proposals and all former railway routes will be protected from inappropriate development to preserve their availability for re-use. Wiltshire once had a reasonable network of railways, both north south routes and east wets The order of bullet points does not indicate their routes. Towns such as Ludgershall, Marlborough, Devizes, Calne, Cricklade and many relative weight. Core Policy 46 does include intermediate towns and villages were rail served. With the need to provide for sustainable measures to promote sustainable transport transport, the need to protect rail routes for future reuse is essential. The Swindon & Cricklade alternatives. The protection and development of Railway can go some way to support this ideal. With the proposed connection at Moredon rail services will be supported, as identified in 2568 SO8 Bridge, the alignment of which should be protected, on the outskirts of Swindon, and a Core Policy 47. Core Policy 48 provides some protected new alignment around Cricklade, it would be in a position not only to provide a examples of rail stations that could be passenger link to Swindon, but also the potential to provide a freight rail service to Chelworth redeveloped. This list is by no means exclusive, Industrial estate, reducing the heavy traffic through Cricklade. As there is then the potential for and other stations could be considered in the the Railway to be extended into Gloucestershire it would be possible for the railway to transport same way. waste to the proposed Wiltshire land fill sites south of the County border and also gravel from the pits in both Wiltshire and Gloucestershire. This will reduce traffic on the A419 and comply with the objective of reducing road transport. Core Policy 48 Strategic transport network, again this centres on road use with rail tagged on as an after thought. With the need to encourage sustainable development rail should be foremost. The bullet point the development and/or improvement of the following rail stations will be promoted and encouraged needs significant enhancement. The County in its West of Swindon study identified the need for a Station at Moredon Bridge, that should therefore be included. It is also necessary as it supports the previously identified missing tourism text. The need for this station is also supported by Swindon Borough. The County has previously campaigned to have a station opened at Ludgershall which would be eminently sensible, and as noted above it should press for the reinstatement of lines to Marlborough, Devizes and several other towns, and of course the development of the Swindon and Cricklade Railway to north of Cricklade to provide passenger and freight services. The reinstatement of long closed rail routes is now well under way in Cross Comment No. Comments Officer Comments Issue Reference By Scotland and is about to start in Wales. England will have to follow their lead at some point. The County should be in a position to encourage this necessary change. Heritage Railways in many parts of the country are now providing local passenger services, over and above their normal heritage operations, such is the importance of the route as a transport link. A growing number of Heritage Railways are now also providing freight services. As identified above the Swindon & Cricklade Railway is in a position to add to the sustainable transport opportunities to Cricklade and north into Gloucestershire. We would suggest the rail bullet points in Core Policy 48 are rewritten as follows. • the development and/or improvement of rail stations will be promoted and encouraged the following will have priority: • Corsham rail station. • Melksham rail station. • Wootton Bassett rail station. • Ludgershall rail station • Moredon Bridge (Sparcells) rail station • the re-establishment of railway services to: • Marlborough • Devizes • Calne • Cricklade These proposals are entirely in accordance with paragraph 6.8.23 and in fact support the concept of additional rail services described there, but which are entirely missing from Core Policy 48 itself. 6.8.23 Work will be undertaken, in conjunction with the Department for Transport, train operating companies and other agencies, to support the opening and improvement of local rail stations and the provision of additional rail services where these facilitate short distance passenger journeys such as those wholly within Wiltshire or to destinations in adjacent areas. Where appropriate, the council will consider financially supporting such initiatives. Priority will be given to new stations at Corsham and Wootton Bassett and an improved service at Melksham. Developments that would prevent realistic rail proposals such as these would be refused planning permission . We would however suggest that it is reworded as follows: 6.8.23 Work will be undertaken, in conjunction with the Department for Transport, train operating companies and other agencies, to support the opening and improvement of local rail stations and the provision of additional rail services such as the reinstatement of the line to Marlborough and that through Devizes, these and similar initiatives will facilitate short distance passenger journeys wholly within Wiltshire or to destinations in adjacent areas. Where appropriate, the council will consider financially supporting such initiatives. Priority will be given to new stations at Corsham, Wootton Bassett, Moredon Bridge Ludgershall and an improved service at Melksham. Developments that would prevent rail proposals such as these would be refused planning permission. The matching paragraphs in the Transport topic paper and T7 will require to be modified slightly to match the above suggested textual changes. Our proposals on minerals are compliant with PPG 13 paragraph 47. On other freight our proposals are compliant with PPG13 p 45, for passengers PPG13 p 48: 58: 73. 73 in particular discusses the need to reopen rail lines.

Hannick Homes and Developments Ltd objects to Core Policy 51 The written justification to PPS9; The comments are noted. The issue of ensuring Core Policy 51 makes it clear that the Environment Agency has concluded that projected protection of the protection of the River Avon SAC is a matter sewage discharges will be compliant with the Habitats Regulations provided that a Nutrient the River of law. Phosphates / nutrients need to be Management Plan is put in place to bring down phosphate levels. The Environment Agency and Avon SAC in managed within the River Avon catchment and Natural England are currently working on the Nutrient Management Plan which will identify accordance hence there's a need to develop a clear works that are required to reduce river phosphate levels and the funding required for these with law; understanding of all sources of pollution (direct works. This is due to report in summer 2011. The written justification also states that it will be at water 2573 and diffuse). The proposed phosphate SO10 that stage when the Council considers whether it is appropriate for development to contribute to resources; management plan is a step towards achieving this the implementation of the Nutrient Management Plan and that the clause in Core Policy 51 Core Policy aim. Paying for the phosphate / nutrient which addresses this issue will be removed if contributions are not required. As it would be 51; management plan is a moot point, but the council inappropriate to seek contributions towards a piece of work (the Nutrient Management Plan) phosphate / recognises that in requesting contributions that has already been undertaken, Core Policy 51 should be amended to reflect the fact that nutrient through legal agreements must be undertaken in contributions can only be required towards the implementation of the Nutrient/Phosphates management accordance with law. Management Plan if that plan identifies such a requirement. planning.

2574 Hannick Response via Jame Lewis. Noted Q22 Cross Comment No. Comments Officer Comments Issue Reference By The policy to balance the workforce and jobs is consistent with the government’s sustainability Government policy on commuting As we have stated, we would question the soundness of a agenda and PPS1. The resulting housing Core Strategy that relies so heavily on reducing the degree of out-commuting (to a zero net 2576 requirement is a minimum and provides the SO8 level) as the key justification for reducing the housing target. Aside from being unrealistic, such flexibility to deliver further housing. It also will be a strategy is not supported by Government policy on housing and travel. reviewed annually to ensure that the objectives of the strategy are being met.

PPS13: transport PPS13 advises that housing is concentrated in the existing principle urban areas (i.e. Salisbury, Trowbridge, Chippenham) to take advantage and support public transport. The point is taken. However, the provision of In rural areas (as in the case of Wiltshire) new housing should be located in local service appropriate, sufficient jobs as close to the place centres as designated in the development plan (in the case of Wiltshire those local service of residence can only be beneficial to the 2579 SO8 centres identified in Map 4.1). These local service centres will act as focal points for the communities of Wiltshire. This will also have the provision of transport and other services and to encourage better transport provision in the effect of reducing car borne travel as far as countryside. This does not amount to an argument against commuting; the purpose is to reduce possible. the amount of car-based travel.

Draft NPPF The draft NPPF aims to support sustainable modes of transport by facilitating economic growth and reducing carbon emissions by promoting accessibility through the location of development (paragraph 84). It also acknowledges that different polices and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural area (page 21 of the consultation draft). The NPPF will need to be read as a whole. None of these statements of Government policy amount to a prohibition on the act of commuting. Current Government policy wishes to discourage car- based travel in favour of other forms of transport that are less CO 2 emitting, including public transport. Emerging Government policy in the NPPF is more realistic about the choices people will have to make and the nature of the labour market. It requires local planning authorities to be realistic about the prospect of discouraging car-based commuting taking into account the impact this may have on the rural economy and supporting the growth of rural businesses (paragraph 81 of the draft NPPF). Topic Paper 17, paragraph 10.4 states that: "Any reduction in the need to commute would be compromised by adopting an overly ambitious housing Comments noted. The strategy includes a requirement". Setting to one side the question whether the target of 44,400 homes (or higher) is number of policies which seek to deliver an overly ambitious one, it is apparent from this statement that the Council is using the issue of sustainable forms of transport. Topic paper 17 commuting as a major component of its argument to justify a reduction in the housing paper sets out the progress made in determining requirement. This is unsound. The aim should be to identify the housing need and then plan to an appropriate requirement and distribution of 2580 meet this by improving public transport provision to reduce car-based journeys if practicable housing for Wiltshire from 2006 to 2026 to inform Question 2 without sacrificing other economic objectives; not to use commuting as a stick with which to the draft Wiltshire Core Strategy. This process beat down the level of housing provision by selectively citing parts of Government policy that considers the strategic objectives for the county might support this. The Council is using the issue of commuting as a non-negotiable planning as well as taking into account local factors and constraint. There is, however, nothing in Government policy that states that commuting is to be aspirations for growth identified through resisted especially if providing a more comprehensive public transport network is impracticable community consultation and rejecting commuting might jeopardise the growth of economic activity. Government policy only tries to discourage car-based commuting where feasible by providing alternative travel options and locating development where it can utilise existing transport networks or make investment in new public transport provision feasible. Conversely, a strategy that promoted development in settlements with good public transport communications and accessibility to major employment centres, or else the potential to improve these through further investment, would constitute a highly sustainable as well as deliverable strategy. Development on land adjacent to significant settlements of growth, such as the expansion of Swindon, Chippenham, Trowbridge and Salisbury, would enable existing public transport systems to be utilised or else car-based journey times reduced. Such an approach is supported by the draft NPPF. Paragraph 112 of the draft NPPF advises local authorities to be responsive to local circumstances and plan for housing accordingly. The paragraph also advises that councils should consider allowing market housing in rural areas to facilitate affordable housing delivery. Cross Comment No. Comments Officer Comments Issue Reference By Development should be located in areas close to local services. Job alignment and zero net commuting The Council's housing requirement is informed by a strategy to provide only enough jobs for the resident population (paragraph 5.17) thereby, presumably, discouraging new migrants from taking those jobs that might increase the demand for new housing from new incomers. The Council's argument also relies on those jobs being taken by existing residents. It is relying on this to happen in order to dampen the propensity for these new homes to be occupied by newly in-migrating households who could commute to work without the county. But the argument is fundamentally flawed as it assumes that all the 27,000 new jobs created over the plan period will be taken solely by local residents, and not by new residents who could be competing with existing residents for these jobs (especially if they are in higher-skilled occupations). The Council cannot guarantee that all these jobs will be taken by current residents. Moreover, because the Council cannot control the occupation of the new housing, its strategy is unrealistic and consequently unsound. The Housing target Current and emerging Government policy The target provides for only 37,000 new homes between 2006 and 2026. This target is clearly inadequate when one considers this against the household projections and what had previously been considered necessary by the South West RS Proposed Changes. When assessing a district's housing requirement the Government has made clear that the policy provisions of PPS3 (Housing) will continue to apply until replaced by its new planning regime. This will include the requirement that the planning system provides ‘a sufficient quantity of housing taking into account need and demand and seeking to improve choice." (paragraph 10). In establishing a housing requirement PPS advises that local planning authorities consider evidence from the SHMA and the Government's most recent household projections as well as advice from the NHPAU on levels of provision necessary to address problems of affordability. The draft Core Strategy fails to do this. Paragraph 27 of the draft NPPF advises councils to use up to date evidence about the economic, social and environmental characteristics and prospects for the area including relevant market and economic signals and land prices to inform judgements about levels of demand. Paragraph 28 refers to the need for housing requirements to meet household and population projections, taking account of migration and demographic change. Paragraph 109 refers to the need for evidence to ensure local plans meet the full requirements for market and affordable housing and paragraph 111 refers to the need to wider opportunities for home ownership as well as planning for a mix of housing based on current and future demographic trends. The evidence The 2008-based household projections indicate the formation of 44,000 new households in Wiltshire during the plan period of 2006-2026 - a figure that exceeds the council's proposed level of provision by 7,000 homes. The figure is in line with the Secretary of States South West RS Proposed Changes - a strategy that had undergone considerable consultation, debate and public examination. The actual number of new dwellings required will be higher than this once an allowance is made for vacancies and second homes. Following the established, albeit simple, demographic method, if we then make allowance for second homes which earlier advice by the NHPAU ( Meeting the housing requirements of an aspiring and growing nation: taking the medium and long-term view , NHPAU, June 2008) suggested might need to be calculated in the order of 0.7% of this target [1] then this would add the need for an additional 308 homes. An allowance for vacancies, including transactional vacancies, is also necessary. Again, drawing upon guidance provided by the NHPAU [2], typically this represents about 3.3% of the total stock at any one time, generating a figure of 1452 vacancies to be accounted for. Added all together (basic projection + second homes + vacancies) this gives a figure of 45,760 homes. This suggests that not fewer than 46,000 homes will need to be provided for in 2006-2026 once an allowance is also factored in for concealed households which the Council has suggested could be in the region of 960 units (see paragraph 5.11 of Topic Paper 17). We would submit that a target of 37,000 is inadequate. In view of the requirement in emerging national planning policy as set out in the draft NPPF, which requires local planning authorities to meet the household projections and take account of migration and demographic change (see paragraph 28) the Council should set a target for at least 46,000 net new homes per year. The residual housing target One further matter in relation to the Wiltshire core strategy is the Council's claim that it has built or has granted planning Cross Comment No. Comments Officer Comments Issue Reference By permission for 17,240 dwellings. Table ES1 of Topic Paper 17 provides the breakdown. This shows total completions across the County at 8,370 (2006 to 2010) with outstanding commitments of 8,869 as at 2010 - total of 17,239. There appears to be a discrepancy with the figures. The level of net completions is not consistent with the net completions recorded by the DCLG in table 122. This shows only 6,380 completions having been achieved between 2006-7 and 2009-10. We attach greater credence to the DCLG's figures than those of the local authority. This means that some 1,990 homes need to be added to the residual housing target for the remaining plan period 2011-2026 (assuming the Council's housing target remains at 37,000). DCLG Table 122: net completions by district 2006-7 2007-8 2008-9 2009-10 West Wiltshire 510 770 _ NA Salisbury 370 460 _ NA North Wiltshire 850 840 _ NA Kennet 330 600 _ NA Wiltshire UA NA NA NA 1650 Totals 2060 2670 1650 6380 The duty to cooperate The Localism Bill and the accompanying NPPF will impose on local authorities a duty to cooperate (see paragraphs 44 to 47 of the draft NPPF). To this end it is unclear to what extent the proposals in the emerging Core Strategy have been discussed with adjoining councils but also those councils that fall within the travel-to-work area of Wiltshire (draft NPPF, paragraph 45). Wiltshire must consider the implications of it policies for these councils consequent to its decision to reduce the housing requirement as a strategy to deter out-commuting. Housing reductions in adjoining local councils In view of the reductions in the housing numbers in those local authorities adjoining Wiltshire (compared to the targets contained in the South West and South East RSs) it is very likely that many households will seek to meet their housing needs in Wiltshire even though their place of work will be in these other districts. The table below illustrates the extent of the reductions in housing in a number of neighbouring authorities. These requirements are either adopted or being proposed and they have been compared to the requirements set out in the SW RS. Comparison of housing numbers in RS and Core Strategies RS Core Strategy Bristol 36,500 26,400 Adopted B&NES 21,300 11,000 South Glos 32,500 21,500 N. Somerset 26,750 13,400 Wiltshire 44,400 37,010 Mendip 8,300 9,130 Swindon 34,200 25,000 West Berkshire 10,500 10,500 Test Valley 10,020 9,320 Total 224,470 163,260 The table above shows that a total of 61,210 homes have been removed from the local development plans of just six local planning authorities either neighbouring Wiltshire or who will be affected by Wiltshire's proposals (only Mendip plans to build more, while West Berkshire has opted to retain the RS target although the 2008-based household projections indicate a need for 16,000 homes over its plan period). This is compared to the numbers that are proposed by the Proposed Changes to the South West RS (or the South East Plan in the case of West Berkshire and Test Valley). The districts of North Dorset, East Dorset, New Forest District and Cotswold also adjoin Wiltshire have yet to declare their respective positions on their housing requirements but the following figures are in their emerging core strategies: RS Core Strategy North Dorset 7,000 5,100 East Dorset 6,400 Undecided Cotswold 6,900 6,000 South Somerset 19,700 16,600 New Forest District 4,140 3,920 Adopted Totals 44,140 31,620 East Dorset has yet to declare its emerging position, but all the other councils have reduced their housing targets by a further 12,520 compared to what is proposed in the South West RS. Such reductions will have unavoidable consequences for Wiltshire and place additional demands for housing in the district. In the case of Test Valley, as the Council acknowledges in paragraph 3.25 of Topic Paper 17, the greatest housing reduction has been made in the south of the district around Andover which has been an area where significant out-commuting has occurred. Any reductions in housing in Andover will only increase housing demand in the east of Wiltshire. International in-migration In paragraph 5.8 of Topic Paper 17 the Council advances an argument that despite the population led requirement generating a need for 43,200 this needs to be treated with caution because it is based partly on an assumption that migration trends will continue as before, when the evidence suggests falling rates of in- migration from the A8 accession countries as a consequence of the recession and the potential that Government policy to restrict further in-migration will cause population to fall further. These are impacts over the plan-period. We would challenge this. Population forecasts are based on assessing the level of net out-migration as well as net in-migration. While the CLG household Cross Comment No. Comments Officer Comments Issue Reference By projection is based on five year migration trends the most recent migration data from Government, post-dates the 2008-based household projections, but indicates that net-migration out of the UK was lower than previously expected. The most recent Government migration statistics ( Migration Statistics Quarterly Report: ONS, May 2011 ) shows that fewer people left the UK than arrived to live (an estimated 586,000 people migrated into the UK in the year to September 2010, compared to an estimated 344,000 people leaving). This appears to counter the argument that district housing requirements can be reduced because the impact of the European recession will result in fewer new in-migrants. The Council's argument assumes that out-migration from the UK would continue at the same rate as before while in-migration fell, when in many respects, the UK continues to be a relatively attractive destination for many and/or opportunities for work contract in the rest of Europe. Indeed, some commentators are anticipating a new exodus from the Republic of Ireland as the young are forced overseas to find work. Section 5 of the Migration Statistic Quarterly Report: ONS, May 2011 shows that in the year to September 2010 the South West is experiencing the largest net inflow of people (20,000) after the South East region (22,600). The South East region is a populous and economically dynamic region where most population and household formation is internally generated. By contrast it has historically been the case that the South West's internal population growth has largely remained static and in-migration has been the most important driver of household formation in the region and provides its labour supply. Thus the Council's argument that reductions in migration will mean that it can by restrict new housing supply and need only provide homes and jobs for existing residents does not appear credible. The region and the county will continue to be subject to strong migratory pressures from households seeking cheaper housing and/or quality of life as they are priced out of the markets of the South East and the West of England city region. This point is reinforced in the recent report by the South West Observatory ( Economic Prediction and Planning Process: a contribution to the current debate about regional planning for housing need after the recession , South West Observatory, January 2011). On page 3 of the report it considers the degree to which people will have left the region owing to the recession, and the implications for any accumulated backlog in under-provision. Drawing on research by Oxford Economics to inform the South West Growth Scenarios, the report observes: "One unknown here is the net number of people, if any, who will have left the region during the downturn. Oxford Economics' take on this is that the rate of in-migration does fall over the recession but it does not turn negative, chiefly because the region's relative attractiveness for migrants has not necessarily diminished relative to alternatives. If that is the case, then future housing growth needs to be greater than a point relationship with economic growth would suggest in order to clear the extant back-log." It is also important to note that the impact of past planning policies designed to restrict growth across the South West region will have probably dampened levels of in-migration, population and household growth than would otherwise have occurred if a more permissive regime had been place. One should conclude from this that these long term migration trends can be expected to continue. This will result in greater housing stress within Wiltshire unless a higher housing requirement is identified. Expression of the housing target and the Housing Market Areas The way the housing target is expressed is extremely unclear. If the Council intends to establish three separate housing market areas through the Strategic Housing Market Assessment each with its own housing target (and requirement to demonstrate a five year land supply for each in compliance with PPS3). This breakdown needs to be articulated clearly and shown in Core Policy 2. It is our view, however, that the council, in keeping with the South West RSS, should adhere to the old district boundaries. It is unclear what the rational is behind splitting the former North Wiltshire DC across two new but different HMAs. We are unclear how land supply be monitored and calculated and how the housing requirements will be determined? Reverting to the old district boundaries would provide continuity and the ability for stakeholders to be able to assess more easily the Council's performance against the proposed delivery rates and to compare this against past performance. The Core Strategy is unclear regarding the relationship between the three strategic settlements and the secondary settlements and service centres, and whether, for example, how development in the strategic Cross Comment No. Comments Officer Comments Issue Reference By centres can complement and enable further development in the secondary and local service centres. We are also unclear what the approach of the Council is to housing delivery in the secondary and local service centres and how Neighbourhood Plans will relate to the Core Strategy targets. Housing targets will need to be apportioned to the local service centres in accordance with table ES1 in Topic Paper 17 and these targets should be incorporated into Core Policy 2. The Council does not appear to have a delivery strategy for these settlements or show how they will contribute to delivering the ‘remainder' target. The Core Strategy should be much clearer on how development will be brought forward in these secondary settlements and it should apportion minimum housing targets so that any Neighbourhood Plan subsequently prepared for these local service centres in the wake of the Core Strategy will be obliged to reflect these numbers (see further comments below in the section on Community-led Plans). The meaning of paragraph ES.22 of Topic Paper 17 is ambiguous. This says that some housing requirements will be provided at a community level but these smaller areas will not be considered in the assessment of supply. Does this mean that these housing requirements will be considered additional to the figures apportioned in Table ES1? Or do these small requirements fall within the scope of the ‘Remainder to be identified' column? This should be clarified. The lack of a proposals map renders the Core Strategy difficult to follow. The Council should produce a proposals map, in keeping with Regulation 27. Strategic Housing Land Availability Assessment (SHLAA) The Council has yet to undertake an up-to-date SHLAA. We note that the new study is not due to begin until October 2011. The last SHLAA was commissioned in 2007 and published in March 2008. It has not been updated since and so is based on outdated survey information. We are concerned, therefore, that the Council has decided its housing target, and its spatial distribution, in advance of preparing a more up-to- date evidence-base. Evidence from the new SHLAA might suggest that the county could support a higher-level of provision and find that the environmental or other constraints cited in the Housing Topic Paper 17, and elsewhere, are not as great as the Council maintains. The DCLG Practice Guidance in paragraph 8 states that the SHLAA is an important source of information to inform plan-making and its assessment will be particularly relevant at the issues and options stage of development plan preparation. We are concerned that the housing target is being presented as a fait accompli with the SHLAA being used to test deliverability of the Council's favoured sites rather than be used as a comprehensive study to test a range of spatial planning options. Previously developed land target Until the SHLAA has been completed we do not understand how the draft Core Strategy can require for 35% of development to take place on previously developed land. This is deciding policy in advance of the evidence. Community led plans We do not support the deferral of decisions relating to the identification of the non-strategic housing allocations (‘the remainder') to community-led or other such plans such as Neighbourhood Plans. Such an approach would not be in conformity with the draft NPPF which defines housing as a strategic priority (paragraph 23) requiring Local Plans to allocate sites to promote development (paragraph 24) and for Neighbourhood plans to be in conformity with the strategic priorities of the local plan. Paragraph 25 encourages local councils to engage with local communities as well as other stakeholders early on to ensure that local plan informs and is informed by emerging neighbourhood plans. Since the non-strategic allocations in the current iteration of the core strategy represent some 50% of the proposed housing requirement outside of South Wiltshire (in South Wilshire the non-allocated supply accounts for about 25% of the requirement) this could add severe uncertainty and delay to housing delivery. Such scope for delay, ambiguity and uncertainty would not be in conformity with the Government's Planning for Growth agenda, and paragraph 24 of the draft NPPF which requires that Local Plans allocate sites to promote development. The Core Strategy needs to be more definitive on how much new housing will be provided at the Community Areas and other secondary settlements. The Core Strategy should also provide a clear strategy that will enable applications on the ‘remainder' sites to be determined. For clarity, the Council should draw together into one section its policies relating to Community led plans and areas. Phasing We do not support the draft policy on phasing. We do not understand the rationale for this and the proportions chosen. Nor do we understand why it would be a problem if development Cross Comment No. Comments Officer Comments Issue Reference By occurred at a faster rate in the earlier part of the plan than the latter. We are also concerned that as the overall residual target is for 19,760 homes (according to the Council's strategy - see footnote 2 on page 26) this would suggest that the Council is intending to grant planning permission for only 1,260 homes over the remaining years of first phase of 2006 to 2016. Given the need for housing in the district we are concerned that a phasing target would effectively impose a moratorium on the granting of new permissions once the pro-rata requirement is met at the end of either the first or second phase. For these reasons we recommend that the phasing policy is deleted. Empty homes We would like to see the evidence base for the number of empty homes in Wiltshire, and by type, so we can examine whether it is justifiable to allow 3,800 empty homes to form a component of the overall new supply (9% of the overall target of 37,010). We would like to know what constitutes an empty home and how these have been counted. [1] Rapid Evidence Assessment of the Research Literature on the Purchase and Use of Second Homes, NHPAU, 2008, p.34 [2] Meeting the Housing Requirements of an Aspiring and Growing Nation , June 2008, p.83

Paragraph 3.2 To give localism real meaning there should be an overarching express strategic objective governing the whole core strategy along the lines of : "In aIl things primarily to meet The policy is by requirement 'strategic' but agree the wishes of the local community at the grassroots (Parish) level". A bottom up approach that what it strives to do, wherever possible, is to 2595 should be adopted throughout the strategy and all other policy making/decisions to reflect the devolve subsequent plan making powers to the Chapter 3. Q22 views of the local residents. This will also provide the flexibility needed to deliver the different local communities themselves. This needs to be wishes of different parishes rather than forcing them into a one size fits all approach. The further emphasised in subsequent versions. categorisations of settlements as proposed in the Core Strategy are not adequate.

All policies within the Core Strategy seek to STRATEGIC POLICY 8 Add at the end of the second sentence: for all members of the 2615 provide for all members of the community unless SO8 community. otherwise stated. STRATEGIC OBJECTIVE 9 Add at the end of the second sentence: In advance of new noted - SO's will be reviewed as part of producing 2616 Chapter 3. Q22 development. next version It is intended that the key outcomes provided the STRATEGIC OBJECTIVE 1 The second sentence should indicate what positive actions will be detail of where positive actions will be taken. 2617 SO1 taken. These will be considered again to ensure the positive actions to be taken are highlighted.

Core Policy 28 OBJECT Exception sites should be available to all villages including those small villages not categorised as small villages. Single dwellings and those built for owner occupation Comments noted. Affordable housing is defined should not be required to make a contribution to affordable housing. The term "affordable" 2642 within PPS3. Further guidance will be provided if SO3 should be defined. Core Policy 29 There is a need to move away from large dormitory housing necessary. estates with no facilities Core Policy 31 The distribution of sites across the County seems uneven. The proportion of the allocation for North Wiltshire should be reduced. Cross Comment No. Comments Officer Comments Issue Reference By Paragraph 6.6.35 OBJECT Delete sentences 4a and 5a of this paragraph. Core Policy 37 The Policy is supported but it is suggested the bullet points should be written in such a form that members of the Public will understand what they mean. Paragraph 6.6.21 Change of wording of paragraph 6.6.21 Delete the first sentence. Substitute: "When working with a designated conservation area, listed building or scheduled ancient monument the Council is committed to work pragmatically with owners to find positive solutions to allow for the adaptation of such buildings." Core Policy 38 Add in final sentence to the Policy as follows: "Wiltshire Council will continue to maintain its Historic Environment Record", Core Policy 4 OBJECT The policy should read as follows:- Protection of the World Heritage Site "The outstanding universal value (OUV) of the world heritage site and its setting will be protected and enhanced by: i. A strong presumption of favour of the protection of the OUV of the world heritage site and its setting. ii Proposals that do not adversely affect ing the OUV of the-world heritage site, its significance, authenticity or integrity, or its setting. This includes the physical fabric, character, and appearance, setting of, as well as or views into or out of, the world heritage site. iii Seeking opportunities to support the positive management to enhance the OUV of the world heritage site through improved conservation, presentation and interpretation will be sought through via suitable development proposals. [The WHS is of OUV: OUV cannot be enhanced - but the WHS can be.] iv The requirement for proposals will be required to demonstrate that full account has been taken of their impact upon the OUV of the world heritage site and its setting and that they proposals will have no individual, cumulative or consequential adverse affect upon them it. This Such proposals may will include sensitively designed proposals for climate change mitigation and renewable energy schemes. Consideration of opportunities for enhancement Comments regarding presentation and the WHS 2646 SO6 should also be demonstrated. [This is already covered under iii above. Paragraph 6.6.32 The noted. paragraph 6.6.32 should read as follows:- "The Stonehenge and Avebury World Heritage Site was inscribed on the UNESCO World Heritage list in 1986 for its outstanding universal value (OUV), comprising their significance, authenticity and integrity . The In order to maintain and enhance its OUV of , the world heritage site itself requires protection and where appropriate enhancement. Not all aspects of the site contribute to its OUV and the UNSECO Statement of OUV of the WHS set out in the WHS Management Plan is a critical resource in reaching decisions relating to defining the significance of the Site and the attributes of its OUV, its elements . In summary the world heritage site is internationally important for its complexes of outstanding prehistoric monuments. The two stone circles at Stonehenge and Avebury, together with the inter-related monuments and sites, and their associated landscapes, demonstrate Neolithic and Bronze Age ceremonial and mortuary practices from of around 2, years of continuous use and monument building. The excellent survival of monuments and sites provides evidence of the creative and technological achievement of the period. Their careful siting in relation to one another, the to astronomical alignments , and topography and other monuments provides further insight; while their continuing prominence today underlines how this period of monument building shaped their landscape. The world heritage site is a landscape without parallel at a national and international level and one of Wiltshire's highest quality environments." Paragraph 6.6.33 Add as a final sentence to 6.6.33 "A future setting study should provide adequate information and appropriate methodology to allow for the assessment of faF the potential negative impact on OUV of proposed development on the WHS and its OUV." [suggested word order change] Cross Comment No. Comments Officer Comments Issue Reference By

Noted and understood. It is the policy of the Core Strategy to protect open countryside and in particular to prevent coalescence between Development Swindon and nearby settlements. Cricklade has west of its own identity and this is recognised as I have concerns about the impact of developments around Cricklade that may impact on rural Swindon. Wootton 2648 important to preserve. This will be taken forward buffers and transport in particular. This is largely in relation to the further expansion of Swindon. Coalescence / Bassett by strong written countryside policies as the Identity of imposition of a rural buffer as a line on a map is villages now prevented by Government guidance. We have however clearly heard the Communities voice on this matter and reflected it in policy. West Wiltshire Transport Concern We find the specific-section consultation process unwieldy; hence our comments are made here. Please consider them in relation to the relevant sections. We have subscribed to the CPRE-led Open Letter to Wiltshire Council opposing its plans for the future of Wiltshire, handed in today (8 August), and refer you to its contents. We do not support the overall approach, based as it is on "predict and provide" rather than "foresee and manage". Some of the rhetoric of sustainability is there, but the concept is used in so broad a way as to be meaningless. There is not enough specific reference to environmental sustainability and its implications for the Core Strategy to be a sound guide to the near-term (15-year) future of land 2651 use, transport and the economy in Wiltshire. The evidence base is not robust. For example, the General comments noted. SO3 employment requirements are based on loose assumptions, and out-of-date employment densities, particularly for B2 land use. There are no high/medium/low forecasts, or sensitivity tests, and the out-turn land use requirements are taken as firm figures, not possibles. There is too little mention of regulating this market by applying environmental constraints. The housing figures are also unsound. They appear to be developer-led. Wiltshire is not a separate ‘state' but part of a wider sub-region in which other, more urbanised authorities have rejected excessive centrally-imposed targets, while Wiltshire has ill-advisedly exceeded them without sound evidence of community support. West Wiltshire Transport Concern We find the specific-section consultation process unwieldy; hence our comments are made here. Please consider them in relation to the relevant sections. We have subscribed to the CPRE-led Open Letter to Wiltshire Council opposing its plans for the future of Wiltshire, handed in today (8 August), and refer you to its contents. We do not support the overall approach, based as it is on "predict and provide" rather than "foresee and manage". Some of the rhetoric of sustainability is there, but the concept is used in so broad a way as to be meaningless. There is not enough specific reference to environmental sustainability and its implications for the Core Strategy to be a sound guide to the near-term (15-year) future of land 2652 use, transport and the economy in Wiltshire. The evidence base is not robust. For example, the See comment 2651 SO3 employment requirements are based on loose assumptions, and out-of-date employment densities, particularly for B2 land use. There are no high/medium/low forecasts, or sensitivity tests, and the out-turn land use requirements are taken as firm figures, not possibles. There is too little mention of regulating this market by applying environmental constraints. The housing figures are also unsound. They appear to be developer-led. Wiltshire is not a separate ‘state' but part of a wider sub-region in which other, more urbanised authorities have rejected excessive centrally-imposed targets, while Wiltshire has ill-advisedly exceeded them without sound evidence of community support. Cross Comment No. Comments Officer Comments Issue Reference By We are writing to you to request an extension to the Core Strategy consultation commenced by Wiltshire Council on the 13th June 2011 and scheduled to close on the 8th August 2011, a total of only 8 weeks. There was little or no warning in the public domain about the consultation process, with only a small section of Trowbridge library set aside to promote the consultation, and a similarly low key exhibition in Bridge House. The Core Strategy was published at a time leading up to the summer holiday period, which has made it difficult for both individuals and orginasations to digest the information, and make comment. The 177 page document comprises local government technical phrases, if you like 'jargon', which is not self explanitory, so is quite confusing and contradictory in parts. Our review of the Core Strategy has been further complictaed by the late publication on the Wiltshire Council's website of relevant documents, some of which were not available until 18th July 2011, a mere three weeks before the end of the consultation. E.g. Draft topic paper 12: Infrastructure Appedinx 2 Community Area Infrastructure Profiles Wiltshire Core Strategy Consultation June 2911, which is another Noted. This consultation is not a statutory process 166 page document. Further relevant documents that have not been easily available are:- and has been carried due to the changes in Proposed Submission Draft Waste Site Allocations Development Plan Document June 2011. national and regional planning. It was felt that a West Wiltshire Level 1 Strategic Flood Risk Assessment. West Wiltshire District Plan First further round of consultation was important to Alteration (adopted June 2004) referring to retained Policies. It should also be pointed out that reflect these changes and allow the public the 2669 Extension Q22 hard copies of the Core Strategy Consultation document have been late in arriving when chance to see how these will affect the Wiltshire requested by the Clerk to the Parish Council. The precedent has already been established for Core Strategy. Wiltshire will accept comments an extension to the Core Strategy consultation by other Councils. Indeed Swindon Borough after the deadline but cannot guarantee how Council (not far from here) commenced their consultation on the 24th March 2011, for eight much influence they will have dependent upon weeks, closing on the 19th May 2011 but it was extended by four weeks to 16th June 2011, a when they are received. total of 12 weeks. Typical consulatation periods are between twelve and fifteen weeks. Can you please clarify the position regarding the consultation as we are now lead to believe that this may not be a 'Statutory Consultation Process'? If this is indeed the case, why was it not made clear at the outset that is it being carried out simply at Wiltshire Council's discretion? On the basis that the assertion above is correct please provide precise details of Wiltshire Council's statutory obligations for the Core Strategy along with the timescales and appropriate activities necessary for Wiltshire Council to comply with its statutory obligations. Despite the question of legitimacy expressed above in teh Core Strategy consultation the case is overwhelming to accept the need for an extension to the consultation process. West Ashton Parish Council therefore formally request that the consultation process be extended in line with the established practice of at least twelve weeks and as already referred to was accepted by Swindon Borough Council (which is also part of Wiltshire). We support the Core Strategy‟s aims. 2. We also endorse much of the demographic analysis such as the rural nature of Wiltshire, the impacts and demands of an ageing population. 3. Consultation 2682 Support Noted Q22 Overall our advice is not unlike that of a doctor‟s to an overweight patient: we feel the Core document Strategy should be smarter, slimmer and more action oriented! Cross Comment No. Comments Officer Comments Issue Reference By Wiltshire is one of the most important areas in the UK for bats, supporting at least 13 of the 17 resident species, including internationally and nationally important populations. Wiltshire supports internationally important populations of all 4 species listed on Annex II of the Habitats Directive (greater horseshoe, lesser horseshoe, Bechsteins and barbastelle) as well as all 6 Priority UK Biodiversity Action Plan species. Bats are unique in their ecological requirements and need a mosaic of different but inter-connected habitats to travel between their roosts and foraging areas. The 4 to 5km radius ‘sustenance' zone around key maternity and hibernation As EPS, bats and their roosts are afforded strict roosts is particularly important to ensure the long-term survival and viability of bat populations. statutory protection under European and British Planning for bats therefore needs to be addressed at an integrated landscape scale to ensure law, which should not be duplicated in local plans. bat populations can use and travel between a network of roosts and foraging areas. A strategic CP50 includes a criteria to protect wildlife from plan-led approach to development is required to ensure key habitat features for bats are disturbance which is defined as including lighting. protected and remain connected into the surrounding landscape. It should also be noted that Wiltshire Council is preparing further guidance in there is the potential for severe impacts to arise to the bat assemblage in Wiltshire due to the associated with NE and BNES which will set out 2683 impacts of lighting associated with development. As such, protection and enhancement of the Bats SO5 more detailed requirements to protect our rarest Wiltshire bat assemblage alongside new development cannot be achieved through provision of and most vulnerable bats from impacts including green infrastructure alone - strategic planning for bats in Wiltshire requires at the minimum lighting. It would be inappropriate to go into this retention of important roosts, commuting routes and foraging areas within a network of dark level of detail in a Core Strategy document. That corridors and zones. The Draft Core Strategy and the Nature Conservation Topic Paper make guidance will be based on all available scientific little to no mention of the potential for severe negative impacts at a strategic level to an knowledge and research, and local expert internationally-important nature conservation asset. As such, it is considered uncertain whether opinion. the draft Core Strategy DPD can be considered to be based on a robust and credible evidence base backed up by adequate fact-finding and research. We have set out a series of comments and suggestions to amend proposed core policies to take into account strategic future development issues affecting the Wiltshire bat assemblage; and to help ensure that the subsequent Submission Draft Core Strategy is ‘justified' and meets the test of ‘soundness' in accordance with the Town and Country Planning (England) (Local Development) Regulations 2004 (as amended) and guidance contained in Planning Policy Statement 12. Would recommend the following key outcome is added for Strategic Objective 5: - Development Too specific for a strategic objective, but an near to important bat roosts will build in the retention of key habitat features within a network of 2685 important issue and polices later in the document Chapter 3. Q22 dark corridors and zones to ensure populations are maintained at favourable conservation cover this. status. The strategy includes policies which relate to the 2687 3.9: Where is strategy for sustainable access to Stonehenge? SO6 World Heritage Site. Comments noted. The Core Strategy process is 6. Adequacy of the consultation Core Strategy: the Core Strategy refers in several places to an iterative process. Evidence gathering in incomplete work or future revisions rendering and therefore this process is incomplete. Wiltshire ongoing throughout and therefore it is appropriate Consultation 2701 Q22 Council (as WCC) complained in the most robust terms to the local PCT when consultation was for further changes and amendments to be made process undertaken on the basis of incomplete information. to the Core Strategy proposals in light of new evidence including consultation feedback. Cross Comment No. Comments Officer Comments Issue Reference By

The Interim Sustainability Appraisal (edition available on 11 July 2011) which we understand was not an external appraisal but one conducted by Wiltshire Council staff endorses several weaknesses which we have noted as follows: p19: Air quality “The LDF policies should ensure that these problems are addressed” p20: Sustainable Tourism and sustainable access to World Heritage Sites p23: There is an assumption that the “current model for transport is correct” p28: The SA does note a number of weaknesses and “Transport is also identified as one of the key challenges which the LDF will have greatest these are either being addressed further to 2706 influence over” p42: Impact of housing provision on transport: “significant investment needs to ensure that development ca take place, or where SA Q22 be made in sustainable transport modes” We have also noted that the Interim SA, which we outcomes are still unknown development is being understand was conducted by Wiltshire Council staff, lists 52 „uncertainty ‟ of outcome for delayed. several strategic objectives: 7 aspects of Objectives1 2 aspects of Objective 2 4 aspects of Objective 3 4 aspects of Objective 4 3 aspects of Objective 6 5 aspects of Objective 7 8 aspects of Objective 8 5 aspects of Objective 9 2 aspects of Objective 10 6 aspects of Objective 15 3 aspects of Objective 16 3 aspects of Objective 17

Core Policy 33 does not currently address the potential for severe negative impacts at a strategic level to nationally and internationally-important populations of bats within Wiltshire. It is recommended that Core Policy 33 is revised to include specific criteria aimed at reducing impacts to bat populations to an acceptable minimum. In an ideal world, data would be available to show the location of all important bat habitat features[1] - and this could be mapped to show zones of constraint for development. However, whilst good data is available on some key roost sites (for example SSSIs and SACs designated as maternity and / or hibernation roosts), available data on key foraging areas and commuting routes for bats is scant. This creates a conundrum - how can these important bat populations be protected without bringing all development to a halt? A reasonable and practical approach is required based on current best available knowledge of our most important sites for bats whilst allowing some flexibility in the policy for new discoveries and data (e.g. newly discovered maternity roosts). The following criteria are therefore suggested for addition to Policy 33: All Community Area Strategic Allocations must consider known records of important bat roosts[2]. Where an important bat roost is located within 4km of a proposed site, further appropriate bat survey work of the proposed Strategic Allocation area will be undertaken during work to prepare the Site 2721 See comment 2683 above. Bats SO5 Allocations DPD; Where a Strategic Allocation is shown through this survey work to support important bat activity including: i. The species associated with the identified important roost; and /or ii. A significant assemblage of bats in terms of either numbers or species a ‘batscapes' map will be produced by Wiltshire Council to show key habitat features to be protected and retained, including a network of dark corridors. This map will be included within the Site Allocations DPD as essential infrastructure to be incorporated into any future development proposals. At the planning application stage, further bat surveys will be required to inform the preparation of a detailed Bat Mitigation Strategy based on the ‘batscapes' map - and it is recommended that further detailed development control policy is developed within the appropriate DPD. This policy should also cover windfall sites wherethe onus will be on the developer to provide sufficient baseline information for sites within 5km of an important bat roost and demonstrate that the bat population can be maintained at favourable conservation status. [1] Habitat features used by bats for foraging or commuting e.g. wetlands, woodlands, hedgerows, species-rich grassland. [2] NB initial draft criteria to identify those roosts that could be classified as ‘important' have been attached - these have been put forward for debate and discussion and are not fixed Cross Comment No. Comments Officer Comments Issue Reference By

Core Policy 28 OBJECT Exception sites should be available to all villages including those small villages not categorised as small villages. Single dwellings and those built for owner occupation should not be required to make a contribution to affordable housing. The term "affordable" 2724 See comment 2642 SO3 should be defined. Core Policy 29 There is a need to move away from large dormitory housing estates with no facilities Core Policy 31 The distribution of sites across the County seems uneven. The proportion of the allocation for North Wiltshire should be reduced.

Core Policy 33 OBJECT The policy should be changed to say: "3. Disturbance - Development likely to increase recreational or other pressures on the Salisbury Plain Special Area of Conservation and the Special Protection Area (SPA) and New Forest SPA and the River Avon SAC may be subject to an Appropriate Assessment of its possible impacts on these sites. Depending upon the outcome of the Appropriate Assessment, the development may either be refused, will be required to deliver an appropriate level of mitigation to offset avoid any potential adverse impacts; or the Council will advise that an alternative scheme or location is sought. Suitable mitigation measures will include: i. Securing management measures for Stone Curlew on Salisbury Plain and surrounding areas. ii. habitat enhancement for Night jar, Woodlark or Dartford Warbler within the New Forest National Park; iii. provision of an appropriate area of CP33(3) The suggested wording duplicates Suitable Alternative Natural Greenspace to deter public use of Nature 2 sites; and iv. securing national legislation and statutory procedures. The access management measures on Salisbury Plain and in the New Forest. Such measures shall delineation of areas of 'special' landscape Biodiversity, be secured through planning obligations and agreements which will be drawn up and approved character is contrary to the national policy landscape, 2725 by the appropriate bodies before permission is granted. All developments proposals shall framework unless this can be clearly justified. For SO5 green incorporate appropriate measures to avoid and reduce disturbance of sensitive and protected this reason it is necessary to review our current infrastructure wildlife species throughout the lifetime of the development. " Core Policy 34 1 Para 6.5.12 This suite of SLAs. Green infrastructure must include paragraph needs to be reviewed in the light of the references to AONB's in the Draft National public open green spaces as a vital component of Planning Policy Framework. 2 Add to bullet point (iii) of the Policy, "through the delineation of the network. highly valued landscapes" . 3. It is not agreed that Special Landscape Areas should be scrapped. They play a valuable part of planning management. Paragraph 6.5.2 Green space needs to be dealt with separately from green infrastructure. Provision of public parks need to be emphasised, not only new sites but the protection of existing open areas. Paragraph 6.5.2 Change to the final paragraph of 6.5.2. to read:- "Wiltshire's natural environment is one of its greatest assets and includes a particularly large proportion of the UK's biodiversity, including some of Europe's most significant sites. The valuable natural environment includes not only sites protected under European Law, but also local sites such as County Wildlife Sites and Local Geological Sites, and features of nature conservation value including .... . " Paragraph 6.6.35 OBJECT Delete sentences 4a and 5a of this paragraph. Core Policy 37 The Policy is supported but it is suggested the bullet points should be written in such a form that members of the Public will understand what they mean. Paragraph 6.6.21 Change of wording of paragraph 6.6.21 Delete the first sentence. Substitute: "When working with a designated conservation area, listed building or scheduled ancient monument the Council is committed to work pragmatically with owners to find positive solutions to allow for the adaptation of such buildings." Core Policy 38 Add in final sentence to the Policy as follows: "Wiltshire Council will continue to maintain its Historic Environment Record". Core Policy 4 OBJECT The policy should read as follows:- Protection of the World Heritage Site "The outstanding universal value 2726 See comment 2646 SO6 (OUV) of the world heritage site and its setting will be protected and enhanced by: i. A strong presumption of favour of the protection of the OUV of the world heritage site and its setting. ii Proposals that do not adversely affec ting the OUV of the world heritage site, its significance, authenticity or integrity , or its setting. This includes the physical fabric, character , and appearance , setting of, as well as or views into or out of, the world heritage site. iii Seeking opportunities to support the positive management to enhance the OUV of the world heritage site through improved conservation, presentation and interpretation will be sought through via suitable development proposals. [The WHS is of OUV: OUV cannot be enhanced - but the WHS can be.] iv The requirement for proposals will be required to demonstrate that full account Cross Comment No. Comments Officer Comments Issue Reference By has been taken of their impact upon the OUV of the world heritage site and its setting and that they proposals will have no individual, cumulative or consequential adverse affect upon them it . This Such proposals may will include sensitively designed proposals for climate change mitigation and renewable energy schemes. Consideration of opportunities for enhancement should also be demonstrated . [This is already covered under iii above. Paragraph 6.6.32 The paragraph 6.6.32 should read as follows:- 'The Stonehenge and Avebury World Heritage Site was inscribed on the UNESCO World Heritage list in 1986 for its outstanding universal value (OUV), comprising their significance, authenticity and integrity. The In order to maintain and enhance its OUV of , the world heritage site itself requires protection and where appropriate enhancement. Not all aspects of the site contribute to its OUV and the UNSECO Statement of OUV of the WHS set out in the WHS Management Plan is a critical resource in reaching decisions relating to defining the significance of the Site and the attributes of its OUV , its elements . In summary the world heritage site is internationally important for its complexes of outstanding prehistoric monuments. The two stone circles at Stonehenge and Avebury, together with the inter-related monuments and sites, and their associated landscapes, demonstrate Neolithic and Bronze Age ceremonial and mortuary practices from of around 2, years of continuous use and monument building. The excellent survival of monuments and sites provides evidence of the creative and technological achievement of the period. Their careful siting in relation to one another, the to astronomical alignments, and topography a nd other monuments provides further insight; while their continuing prominence today underlines how this period of monument building shaped their landscape. The world heritage site is a landscape without parallel at a national and international level and one of Wiltshire's highest quality environments." Paragraph 6.6.33 Add as a final sentence to 6.6.33 "A future setting study should provide adequate information and appropriate methodology to allow for the assessment of for the potential negative impact on OUV of proposed development on the WHS and its OUV." [suggested word order change]

The Cotswolds conservation Board was established by Parliament in 2004. The Board has two statutory purposes: 1. To conserve and enhance the natural beauty of the AONB : and 2. To increase the understanding and enjoyment of the special qualities of the AONB In fulfilling these roles. The Board has a duty to seek to foster the economic and social well-being of Noted. Responses to specific comments are 2729 people living in the AONB. The Cotswolds Conservation Board having examined the document SO5 provided in the appropriate sections. wishes to make the comments as detailed in the attached appendix by way of response. It should be noted that not all elements of the public consultation document have been responded to, only those that are considered to have a direct or indirect impact on the Cotswolds Area of Outstanding Natural Beauty or its management, or the Cotswolds AONB conservation Board.

Sustainable 2733 CP27 is supported by the Cotswold Conservation Board. Support noted. SO2 construction.

CP28 - Whilst supportinve of this policy the Cotswold Conservation Board is not clear why the exceptions site provision in PPS3 is restricted to 'large and small villages' as defined in CP1. There may be smaller settlements in which housing neesd surveys indicate a need for a small Comments noted. Consideration will be given to 2734 SO3 number of affordable homes. Policy CP28 would prevent this need being met. Furthermore the expanding the exceptions site policy. policy should not rule out the possibility of allocating 1% housing sites as part of the core strategy allocations, where local housing needs are demonstrated.

CP31 - Criterial II of the policy shoud read 'unacceptable impacts on the character and 2735 appearance of the surrounding landscape Will can be Minimised sucessfully Successfully Comments noted. Changes will be considered. SO3 mitigated trhough the sensitive and appropriate design of the scheme. Cross Comment No. Comments Officer Comments Issue Reference By

Because the WANHS Building & Monuments Committee have the delegated authority from the Council of British Archaeology to respond direct to the Council concerning planning applications related to listed buildings and monuments, a detailed response is being made here concerning the issues and potential impact on the landscape, listed buildings and other heritage assets within the county. With the imminent replacement of PPS5 by the National Planning Policy Framework it is appropriate to respond to the core strategy consultation across all its elements 2739 that potentially impact on the historic environment, monuments, heritage landscapes and listed Comments noted. SO6 buildings within the county of Wiltshire. This response is made in free written format rather than use the restrictive on-line insertion format which has been designed to influence responses in a particular way (especially the detail change of specific words etc as this methodology does not necessarily allow the impact of the consultation response to be meaningful). Under the consultation protocols that have been adopted for this public consultation, this response methodology is acceptable.

General comments on the overall document: Whilst the Wiltshire Core Strategy provides a reasonable approach to ensuring sustainable development within Wiltshire there are however some areas that we would like to highlight where there may be additional factors to take into consideration in order that the historic environment be protected by the "owners" as well as being made available and accessible to visitors and interested parties. In particular, the areas that may need some review of the assumptions and require a review of the proposed approach include: 1. The bases of the demographic assumptions would appear to be based on the 21 Comments noted. The council will always seek to 2741 SO3 Census. There have been many changes that have affected the employment and habitation use the most up-to-date evidence available. demographics since then and the forward looking strategy should be based on the 211 Census data. Can you assure us that the final strategy document will utilise the 211 census data and not the outdated 21 Census data? 2. There is a real challenge in trying to ensure that development for housing and employment work together to discourage long travel-to-work distances, and the importance of neighbourhood plans in protecting historic buildings and landscapes via local strategies to achieve this will provide some cultural conflicts.

1. The climate change debate and actions have an impact on how the land and building stock are be used and this will impact on the changing requirements of the land use and current building stock changes. Between now and 226 there may be a stabilisation of temperatures or even possible lowering of temperatures affecting the UK and Wiltshire and not an increase, thus the changes to listed buildings for instance to maintain habitability may require a relaxing of some of the current advices regarding the fitting of double glazing. 2. Wiltshire has the highest percentage of listed housing stock in the country, which brings particular pressure on the development of existing buildings for alternative uses. This will apply especially with the "infill only" priority in settlements, towns and villages, and the associated listed buildings and Comments regarding climate change noted. All monuments and their landscape settings, and there may be potential conflicts between new development will need to provide for the 2743 preservation and employment/housing aspirations. Small scale developments must therefore necessary direct and, where appropriate, the in- SO6 contribute to infrastructure development to solve current traffic movement problems to reduce direct infrastructure requirements arising from the the impact on fragile historic buildings and there setting. (e.g. the A4 road running through the proposal. Comments regarding the WHS noted. centre of Calne carrying increased local traffic from the housing development expansions) Section 3.9 The statement “Sites will be protected from inappropriate development” could be made more meaningful if this qualitative term is defined for example as: “Inappropriate”: Any development that does not match the style or vernacular features of a WHS (World Heritage Site) SSSI (Site of Special Scientific Interest), a listed building or other designated protected area, and that does not provide improved use or access to the site for the current inhabitants or visitors. Section 6.6.19 (Core Policy 38) The statement declares a need to protect listed buildings, scheduled monuments, Stonehenge and Avebury WHS’s and OUV’s etc which is Cross Comment No. Comments Officer Comments Issue Reference By correct. What would be helpful is an intention that makes available, and also interprets, these sites for the public (residents and visiting tourists). The encouragement of functionally designed interpretation centres, museums etc. is vital to the preservation and development of the County’s heritage and the related tourist industry. It is in this context that the identification of the need to invest Community Infrastructure Levy funding in Place Shaping is extremely welcome, as the measures proposed will enhance communities and enable the preservation and interpretation of the historic environment that makes Wiltshire such a special place in which to live and work.

Section 3.5 Because of the influence policies will have on land usage, soil preservation and use Comments noted. It is not considered that the of listed building stock, the climate change statements need to acknowledge the short period of proposed policy would be inappropriate if there the strategic plan (to 226) as there are growing indications that over the next circa 7 years were to be a temporary cooling in the climate: the (which exceeds the period of this strategic review) the climate may be cooler due to low first part of the policy seeks to ensure that Sustainable sunspot activity - an established and accepted cyclic phenomenon seen in the archaeological buildings are well insulated and air tight (thereby construction, 2751 record. Assumptions on achieving building energy efficiencies may be correct for new builds but SO2 minimising heat loss in the winter), as well as listed the changes to the existing building stock are more likely to require a different approach. This maximising cooling in the summer. Consideration buildings. particularly impacts the high proportion of listed buildings and other historic "worth preserving will be given to making specific reference to the buildings" that will be used to create homes within the identified areas. The particular needs to need to use appropriate sensitive approaches improve the insulation of these buildings will for instance require acceptance of double glazing and materials in the case of listed buildings. units in suitable natural material frames etc.

CONCLUSION This current draft core strategy is deeply flawed. It has a ‘democracy deficit'. It does not keep to its stated Community Area Geography. It uses old RSS assumptions with new language to conceal this. Chippenham does not match another Principal Settlement, a cathedral city, Salisbury; its scale is a recently enlarged (dormitory) Market Town. It goes against the spirit of localism which Wiltshire Council purports to support, in ignoring community voices and keeping the process poorly advertised. Too much reliance has been put on Chippenham Vision in this process, who act in a deeply clandestine manner. I can not Overall 2755 commend either of the two Options for Chippenham, and within the Calne Community Area Noted. Q22 Strategy proposals, there were no plans for an additional level of housing in the Bremhill Parish, which relates to development in the North East and East. I am also signed up to the Open Letter of several community groups and organisations which was presented at Trowbridge, to Councillor Sturges, on 8 th August, 2011. There is much disquiet about this draft core strategy. Please think again, and with the community genuinely participating not being rail-roaded. We all care about Wiltshire and the future of young people who will live in the area. We want to protect it for them as well as attend to the limited planetary resources. Cross Comment No. Comments Officer Comments Issue Reference By Introduction Royal Mail Group Ltd (Royal Mail Group) is responsible for providing efficient mail sorting and delivery for Wiltshire.Royal Mail Group, advised by BNP Paribas Real Estate, has reviewed the Wiltshire Core Strategy consultation document for which the public consultation period ends on 8 August 2011. Royal Mail Group sets out below its response to the consultation document. This short response identifies Royal Mail Group's key existing infrastructure in the County. This identified infrastructure is essential to Royal Mail Group in continuing to provide Mail collection and delivery services to Wiltshire throughout the Core Strategy period. The Royal Mail Group infrastructure that is identified below and the operations carried out from them will require protection from development and the impact of nearby development. Whilst it is noted that the consultation document is a high level and strategic in nature, it is requested that Wiltshire Council has due regard to the content of these representations in developing the site specific County's Core Strategy. Interrelationship between Royal Mail Group facilities and residential development Of particular concern to Royal Mail Group is the possibility of residential development being allocated / grated planning permission on land adjacent to existing Royal Mail Group sites. Royal Mail Group's mail handling facilities are busy operational sites that can generate high levels of activity, noise and light pollution often at anti-social hours. Royal Mail Group - Representations to Wiltshire Core Strategy Consultation August 2011 2 Royal Mail Group's experience of new residential units being built in close proximity to busy mail handling centres is that these two land uses are totally incompatible and often result in complaints about disturbance being made to Royal Mail Group and /or Local Planning Authorities by the owners / occupiers of the new residential units. Royal Mail Group's position is that residential development adjacent or close to existing mail handling facilities should not be allocated or permitted by Local Planning Authorities. If such development is permitted by a Local Planning Authority that is made aware of Royal Mail Group's position in advance of determination of the planning application, then Royal Mail Group will not take any action in response to any complaints that are received from future owners/occupiers of new residential units. Sensible land use planning and development control 2760 Noted Q22 by Local Planning Authorities should prevent such complaints from arising. Traffic capacity Royal Mail Group relies mainly on road transport for all its bulk mail collection and delivery to its facilities. The efficiency of mail handling operations in some existing Royal Mail Group facilities is very sensitive to changes in traffic capacity in the surrounding highway network. Delays from small increases in congestion can have substantial detrimental impact on Royal Mail Group's ability to meet mail collection and delivery timetables. Therefore, in planning new development, appropriate regard should be had by Wiltshire Council to traffic impact on existing Royal Mail Group operations from its existing infrastructure as identified below. Royal Mail Group - Representations to Wiltshire Core Strategy Consultation August 2011 3 Key existing Royal Mail Group infrastructure in Wiltshire The key elements of Royal Mail Group infrastructure in Wiltshire that will require protection from development and the impact of nearby development. Amesbury Delivery Office 20 LONDON ROAD AMESBURY SP4 7EW Calne Delivery Office 22- 24 HIGH STREET CALNE SN11 0BP Devizes Delivery Office SHEEP STREET DEVIZES SN10 1ZZ Salisbury Delivery Office FISHERTON STREET SALISBURY SP2 7QP Tidworth Delivery Office KOHAT ROAD TIDWORTH SP9 7BN Marlborough Delivery Office BACK LANE MARLBOROUGH SN8 1ZZ Wootton Bassett Delivery Office MARLBOROUGH ROAD WOOTTON BASSETT SN4 7WB Trowbridge Delivery Office 1A ROUNDSTONE STREET TROWBRIDGE BA14 8DA Warminster Delivery Office 71 MARKET PLACE WARMINSTER BA12 9AX Westbury Delivery Office KINGDOM AVENUE WESTBURY BA13 4EZ Bradford on Avon Delivery Office TREENWOOD INDUSTRIAL ESTATE BRADFORD ON AVON BA15 2AA Chippenham Delivery Office BUMPERS WAY, BUMPERS FARM CHIPPENHAM SN14 6EX Wootton Bassett Vehicle Park TEMPLARS WAY INDUSTRIAL ESTATE WOOTTON BASSETT SN4 7WB Marlborough Vehicle Park 101 HIGH STREET MARLBOROUGH MARLBOROUGH SN81LW Royal Mail Group - Representations to Wiltshire Core Strategy Consultation August 2011 4 Plans showing the extent of these sites are attached. Royal Mail Group asks that these representations are taken into account by Wiltshire Council in progressing the Core Strategy and in particular the future site specific documents that will follow. However, should you have Cross Comment No. Comments Officer Comments Issue Reference By any queries then please contact Daniel Parry-Jones of BNP Paribas Real Estate (daniel.parryjones@ bnpparibas.com) in the first instance.

Concern is expressed by the Cotswold Water Park Trust (CWPT) regarding the omission on the whole of the Cotswold Water Park and the Cotswold Water Park Masterplan. Considerable Consideration will be given to adding a specific Cotswold 2762 opportunities exist in the CWP to deliver much of the spatial strategy but such opportunities are policy on the Cotswold Water Park for the pre- SO5 Water Park. likely to be missed unless the Core Spatial Strategy incorporates the themes of the masterplan, submission draft core strategy. South West Nature Map in the CWP, and the CWP Biodiversity Action Plan.

The following should be added to Strategic objective 4: - to build resilient communities : Green infrastructure policies will have resulted in open space for people to take healthy open air noted - SO's will be reviewed as part of producing 2765 Chapter 3. Q22 exercise and recreation being available to everyone and no-one will live more than three next version hundred metres from accessible open space of high quality The following should be added to Strategic objective 4: - to build resilient communities : Green infrastructure policies will have resulted in open space for people to take healthy open air exercise and recreation being available to everyone and no-one will live more than three hundred metres from accessible open space of high quality. Strategic Objective 4, p3.7. The identified shortfall in the range of sport, leisure and recreation facilities can be addressed in the Cotswold Water Park; significant opportunities exist to enhance all of these in the CWP and existing partnerships and operators are present to deliver necessary work and facilities. Such facilities can be shared with neighbouring counties and be incorporated into tourism and visitation. The plans for the paddle sports centre and nature reserves at Cleveland Lakes, Ashton Keynes, along with an array of facilities for a very broad range of outdoor recreation activity will deliver significant improvement to people's health, wellbeing and quality of life. Agree access to open space is importunate and Water sports, walking cycling and horse riding trails, activities that engage people with the polices will be included to cover this issue. noted - 2766 natural world and volunteering opportunities will sit alongside activities such as water-skiing and Chapter 3. Q22 SO's will be reviewed as part of producing next orienteering.. It is clear that there is a strong need for water sports facilities outside of version membership-only clubs and groups. Opportunities for this should be developed. Strategic Objective 4, p3.7. Further work will be necessary and desirable to dovetail forthcoming neighbourhood plans with existing policies and guidance specific to the CWP, including the CWP Masterplan, CWP Biodiversity Action Plan etc. The CWP Trust, through the development of the recent Heritage Lottery Fund application, has already drawn together many of the parish and town councils in the area; these works should be progressed further to draw together common objectives across the CWP in a coordinated and strategic fashion. Strategic Objective 3, p3.6. The nesting requirements of birds such as Swift, House Martin, House Sparrow and the roosting requirements of bats such as Pipistrelle, Natterer's, Brown Long-eared and Horseshoe bats are incorporated into new buildings at design stage. New builds must provide opportunities for these species, all of which are in decline resulting from the lost of nesting sites Cross Comment No. Comments Officer Comments Issue Reference By resulting from changes to building regulations. Strategic objective 5, p3.8 First strategic outcome should read: Where possible, development will be directed to the places most suitable for it and designed to fit with, protect and enhance the place where it is set, especially where this will enhance natural and heritage assets. Development should take place in sensitive locations only when it delivers net gain to the location. Strategic objective 5, p3.8 Eighth strategic outcome should read: Recreational activity in places where heritage and wildlife assets may be at demonstrable risk from human activity will be managed so that the two interests are best served and where there is a demonstrable irreconcilable conflict between the two, the human activity will be sited elsewhere. Strategic objective 5, p3.8 Ninth strategic outcome should read: The landscape character of Wiltshire and its diversity will have been protected and enhanced, contributing to the delivery of landscape scale plans and projects. Strategic objective 5, p3.8 Final strategic outcome should read: The role of areas under special management for their environmental quality, such as the Areas of Outstanding Natural Beauty, Local and National Nature Reserves, Country Parks and the Cotswold Water Park should have their special role in delivering biodiversity and high quality natural environment reflected. Strategic objective 5, p3.8 As with much of this draft of the Wiltshire Core Strategy, there is little or no mention of the Cotswold Water Park Biodiversity Action Plan, which continues to be an effective policy driver, delivery and fundraising tool; the BAP is effectively delivering the Biodiversity Vision for the CWP at a landscape scale. It should not be omitted from this document. Central to landscape-scale biodiversity delivery in the South-West is the South- West Nature Map, which is still a current policy tool. The Biodiversity Vision for the CWP will and is delivering Nature Map Strategic Nature Areas (SNAs) in the CWP. It should further be noted that the County BAP is subject to considerable change resulting from the forthcoming England Biodiversity Strategy; county LBAPs are likely to see considerable revision and change, and as such, so will the CWP BAP. The CWP BAP has been an effective delivery mechanism for many years and following the development of the Biodiversity Vision, based upon South West Nature Map, has been strengthened further. The Wiltshire Core Strategy should make linkage to the CWP BAP. The CWP BAP also supports and prioritises species and habitats not included on the County BAP; these habitats and populations should be considered in developments within and adjacent to the CWP. This includes a nationally & internationally important winter waterbird population (exceeding SSSI and Special Protection Area criteria), a nationally important Black Poplar population, regionally important populations of dragonflies and damselflies, nationally noted populations of Barberry Carpet Moth and nationally important populations of European Protected Species such as Otter, Water Vole, 14 species of bats etc. The CWP BAP includes targets for the restoration, enhancement and delivery of local habitats, linked to Nature Map. These targets and actions should be considered in development and delivery within the CWP, including the delivery of sports and recreation facilities. The delivery of sports and recreation facilities in the CWP should not be at the expense of natural assets, species and habitats and management of the assets and the activities needs to ensure the two factors are integrated and harmonised to accord with modern management practice. The CWP is to be a focus and case study for the future management of recreation in areas of wildlife sensitivity. Additional planning powers and focus will be required to ensure that natural assets are safeguarded from inappropriate development and activities . It is encouraging to see linkage to natural green corridors and Green Infrastructure; the CWP BAP and Biodiversity Vision is ideally placed to support such delivery. Such delivery will likewise feed into landscape enhancements. A focus should be placed upon the protection, restoration and enhancement of the Thames floodplain, to assist with climate change buffering, reducing the impact of flood events and of low flows in summer months. Key factors include mineral extraction, vegetation management, water supply abstraction and inappropriate built development. Some recent development in the CWP in recent years has damaged natural assets, including designated sites such as SSSIs and County Wildlife Sites. Following a recent review of Standing Open Water CWS in the CWP, further work will be needed to promote and support local CWS as well as increase the network. Strategic Objective 6, p3.9 This key outcome should also be included: New development will incorporate design and construction Cross Comment No. Comments Officer Comments Issue Reference By techniques that reduce environmental footprint of the development, both in its construction and in the consumption of environmental assets by thise inhabiting the development. The techniques will include sustainable urban drainage, high performance energy conservation and low carbon usage but include other appropriate techniques as well. The support and enhancement of floodplains and their natural function is welcomed, however, considerable work will be needed to achieve this. The Natural function of the Thames floodplain needs further protection from inappropriate development, widespread mineral extraction in the floodplain, excessive abstraction and poorly managed surface runoff from Swindon. These factors and others are creating a degraded floodplain with low summer groundwater levels, significant flood events in winter and summer and loss of flood storage capacity. Floodplain restoration could support local communities, food production, species and habitats worth considerable sums of money to the local economy. Mineral restoration can restore aspects of the floodplain, restoring flood storage capacity, so long as mineral permissions are restoration-led, delivering floodplain enhancements and restoration. Changes to rainfall patterns will also cause low flows in summer months; this is already evident and is linked to flood storage capacity. Low flows caused by excess abstraction and disrupted groundwater flows, frequently lead to increased surface runoff and flood events in the event of heavy rainfall.

6.2 SO2: to address climate change Core Policy 26: Sustainable Construction and Low-Carbon Energy The requirements for birds and bats in buildings to be incorporated into all development, including birds such as Swift, House Martin, Swallow, House Sparrow, Tree The proposed Core Policy 33 (Biodiversity and Sparrow, Starling, Barn Owl, Kestrel, and bats such as Soprano Pip, Common Pip, Natterer's, geodiversity) in the June 2011 consultation Brown Long-eared, Serotine and the Horseshoe bats. At present, architects and planners 2769 document states that 'All development should Biodiversity. SO2 appear to take the view that these species and their needs are incompatible with current seek opportunities to enhance biodiversity' and building regulations and sustainable construction. They are not and don't need to be. Please therefore covers this issue. see, for example, Biodiversity for Low and Zero Carbon Buildings, A Technical Guide for New Build. Dr Carol Williams, Bat Conservation Trust. RIBA Publishing/Bat Conservation Trust. All future development to represent an enhancement for these species.

I refer to your email dated 5 th August 2011 made in response to the Parish Council request for an extension to the Core Strategy consultation. In your response you noted that ‘the consultation had been widely trailed through a range of media resources'. The Parish Council would like to comment on the use of some of these resources and question their effectiveness Comments are noted. Every effort has been in reaching ‘the every day man in the street' - As far as the Parish Council are aware the made to ensure that as many people as possible consultation was not advertised in the Wiltshire Times prior to 13th June and was possibly only are aware of the Core Strategy and have the advertised on the 17 th of June (1 week into the consultation) as a result of a phone call from a opportunity to comment on the proposals. This campaigner? Can you please provide details of any other dates the consultation was includes via the local media, web and advertised, and the name of the publication? Area Boards are only generally attended by consultation events. All those people who have specific groups, organisations and Councillors, and tend not to attract many members of the registered and/or previously commented on the general public. ‘Community Area Exhibitions' - The public exhibition in Bridge House and on Core Strategy proposals will have been contacted Consultation 2773 Library poster boards were very low key events and did not appear to be particularly well via email/letter. Local media are briefed and Q22 process attended. ‘People have been contacted directly via letter or email providing opportunity to press releases are issued to the local media, but comment on the draft Core Strategy' - By this statement we would have hoped that you meant there is no guarantee that they will act upon them. contacting directly those people living adjacent to the proposed sites suggested for The consultation began before the school development. However this does not appear to have been the case -on the day "Points West" holidays on June 13th and ended on 8th August. covered the open letter handed in to County Hall, one resident spoken to who lived in Barley All the events were held before the school Rise knew nothing about the "Core Strategy", and they lived immediately adjacent to the holidays and so it was felt that this gave the proposed "Green Field" development East of Trowbridge - so it appears the Council have opportunity for as many people as possible to missed those who will be most affected. The Parish Council would also like to further question comment before they went on holiday. the timetabling of the consultation - School holidays from 22/7/11 impacted on the 8 week consultation period and effectively reduced it to 5 weeks (1 week because of late Wiltshire Timesadvert and 2 weeks into the school holidays). The Wiltshire Council website indicates Cross Comment No. Comments Officer Comments Issue Reference By ‘December 2011 - February 2012 for the formal consultation', presumably this is the proposed Statutory Consultation period of the normal 12 weeks. However it includes the Christmas 2011 holiday period of two weeks, and we therefore suggest that the period should be formally set at fourteen weeks to take this into account. The Parish Council thank you for acknowledging the issues we raised in relation to the style and content of the document, however we still stand by our opinion that many of the Core Strategydocuments were cumbersome to handle and contained references to other sources, which made them extremely difficult to comment on effectively in such a short time. During cross referencing we also found several examples of statements which were contradictory and ambiguous. I hope you will find some of these comments helpful when preparing for the next round of consultations.

5.3 Trowbridge Community Area Strategy (5.3.3) Bullet point 2 – ‘… Town centre growth should be a priority with Greenfield development being phased towards the end of the plan period’. See comments made for question 2, bullet point 2. Bullet point 3 – ‘… significant and focused improvements to the A350 particularly at Yarnbrook and West Ashton where existing junction arrangements are over capacity ..’ (Also see comments made for question 2, bullet point 1). This stretch of the A350 requires major work, and possible re-routing rather than the proposed widening of the junctions which has been suggested – this work can hardly be described as ‘significant improvements’ and would have little effect in alleviating congestion and improving the flow of traffic. Following the Westbury Bypass Inquiry in 2009 and the subsequent cancellation of the scheme, the Inspector made several references and recommendations in his report to the inadequacy and serious shortcomings of this stretch of the A350 which have yet to be addressed. The Parish Council therefore insist that serious investigation needs to be carried out, and a comprehensive and lasting solution to the congestion problems identified, before any Noted. The majority of the issues highlighted will future proposed development is even considered in the area. The recommendations from the be addressed in masterplanning for the site. No investigation should then be included in detail in the final Core Strategy Document. Bullet point development will take place in advance of 4 – The Parish Council recognises the need for a further secondary school in the Trowbridge transport solutions and school development being area, however considers that the proposed siting South East of the town adjacent to a agreed. Development will not take place on flood floodplain is seriously flawed. It suggests that a site to the North East (or indeed North West) of risk zones 2 & 3 and ancient woodland. However, 2774 the town nearer Hilperton and the Paxcroft Mead area where the majority of the pupils who the site includes these areas as a part of the legal Trowbridge would attend the school live, and therefore where the need is greatest, would be a better requirements of the document. The vision is location. Bullet point 6 – The Parish Council strongly believes that every village surrounding exclusively focused on town centre regeneration Trowbridge has a separate and distinct identity which needs to be maintained and protected and thus would not include sites on the periphery and should be clearly taken into account in any planning proposals. Bullet point 9 – ‘… should of Trowbridge. Nevertheless, these comments be sensitive to constraints, such as … SSSIs, Ancient Woodland … and areas at risk of have been passed on to the relevant officer for flooding….’. The Parish Council strongly disagree with the statement that the land proposed for consideration. development to the South East of Trowbridge is relatively unconstrained - the proposed residential allocation of 2650 dwellings, and 30 hectares of employment land would be located in the vicinity of two Ancient Woodlands - Green Lane Wood and Biss Wood, both of which are home to the protected Bechstein Bat and subject to European Law. The site is also adjacent to recognised floodplains as already mentioned. Bullet point 18 – The Parish Council questions the need for extra childcare provision in the West Ashton Area. Map 5.5 of the Trowbridge Community Area – This map is very misleading - it should also include details of all the existing allocations for development as well as the proposed new ones i.e. the proposed business park, which was rejected by West Ashton when first proposed and the 650 houses already approved to the South East of the town. Question 6 – The Parish Council does not agree with the proposed area of opportunity. It considers that throughout the consultation document the definition of ‘Trowbridge area’ is very fluid, and needs further clarification. The 18 areas of Cross Comment No. Comments Officer Comments Issue Reference By opportunity identified in the ‘Trowbridge Vision’ are all situated in the central area of Trowbridge, and no consideration is given to the surrounding villages. In summary the Parish Council consider that there is insufficient detailed information in the Core Strategy Document to allow any further detailed comments to be made. The Core Strategy simply shows that Wiltshire Council is using an out of date philosophy, namely “large scale housing developments as the approach, when it is NOT the case, and would do well to recognise their mandate is to represent citizens now. However, an important point that must be included is a requirement to place greater emphasis on identifying and developing brown field sites for housing and employment opportunities in and around Trowbridge rather than proposing such developments on existing green field sites. There are already many empty employment buildings in the area that indicate that there is not a lack of employment space.

This note constitutes formal advice from W&S CAF. As a body listed under Section 94(4), Wiltshire Council is required in accordance with Section 94(5) of the Countryside and Rights of Way Act 2000, to have regard to advice from this Forum in carrying out its functions. Overall the Forum is supportive of the objectives and policies contained within the draft Core Strategy. The principal criticism the Forum has of the document, is its lack of direct reference to the role that access to the countryside can contribute to the improved wellbeing of communities. We believe that the rights-of-way network is a key strategic asset that needs to play a substantially greater role in spatial planning for the future. We recognise that the Core Strategy document is necessarily a high level overview within the Local Development Framework and that the detail of how access may be delivered and improved in the context of both spatial and community planning should be developed in lower tier documents and especially in plans arising from the implementation of Core Policy 35. Nevertheless, we believe that if this approach is to have any coherence it is important that the Core Strategy contains suitable references throughout to this specific subject area. We propose the following textual amendments: Paragraph 1.3, fifth bullet point - "... development of green infrastructure and improved access to the countryside to support the health and well being of communities..." Paragraph 1.11, additional bullet point - " the Wiltshire Rights-of-Way Improvement Plan " Paragraph 2.2 - "... more than 16,00 listed Noted. The majority of the comment concerns buildings, more than 240 conservation areas and the Avebury and Stonehenge World Heritage specific changes to wording in each section Sites; together with in excess of 6,000 Kilometres of public rights-of-way ." Paragraph 2.19 - Number of 2775 Numerous. regarding green infrastructure and public rights- Q22 "...opportunities to enhance these significant assets maximised as well as improving people's Issues of-way. These amendments have been passed to engagement with the natural world. " Paragraph 3.5, Key Outcomes, first bullet point - "... the relevant officers. reduction in the need to travel, together with improved facilities for walking and cycling will have contributed..." Paragraph 3.7, Key Outcomes, sixth bullet point - "... shortfall in the range of sport, leisure, recreation facilities, and access to green space will have been addressed." Paragraph 3.8, Key Outcomes, fourth bullet point - "A network of multi-functional green infrastructure including a first class rights-of-way network will have been developed..." Paragraph 3.12, Key Outcomes, fourth bullet point - "... leisure and open-space, green infrastructure including access to the countryside , libraries..." Paragraph 4.33, 3 Place Shaping Infrastructure, fourth bullet point - "...green infrastructure including access to the countryside. " Paragraph 6.1.4, fifth bullet point - "...tourism opportunities including exploiting access to our countryside , which will add value..." Paragraph 6.1.17, fourth bullet point - "measures for the reversion of parts of the site to a natural state. In these circumstances consideration will be given to the restoration of historic rights of access to the countryside. " Paragraph 6.1.26 - "... add value to the local economy. Additionally, it is recognised that Wiltshire Council can directly contribute to the rural attraction of the landscape by improving access to the countryside through the rights-of-way network. " Paragraph 6.2.1, fourth bullet point - "...more sustainable forms of transport are supported, including improved opportunities for walking and cycling, and so help reduce..." Core Policy 27 item v. - "impact on the local transport network , including Cross Comment No. Comments Officer Comments Issue Reference By public rights-of-way ." Para 6.4.3, sixth bullet point - "...community facilities such as shops, open space and access to the countryside , recreational facilities..." Core Policy 33, final paragraph - "All development should seek opportunities to enhance biodiversity and facilitate public engagement with the natural environment. " Core Policy 42, bullet point two - "... alternatives to the use of the private car , including greater opportunities for walking and cycling ."

Policy 39; Although the benefit of achieving a minimum net density of 3dph is to be encouraged it should be caveated to ensure that all development is contextually informed and consequently Comments noted. Consideration will be given to 2808 SO6 such a threshold will not be insisted on as a 'minimum' figure without the appropriate flexible amending the density policy. application of policy, to ensure attractive places to live. The maps within the Core Strategy are not meant Persimmon Homes and Mr B Hocken note that map 5.17 should be revised to show the to act as proposal maps but simply figures similar 2817 national and international wildlife designations. It is potentially misleading to show them all as Maps Q22 to a key diagram to make the document legible County Wildlife Sites. for the public. Persimmon Homes and Mr Hocken object to Core Policy 51 in respect of phosphate pollution. Noted. Measures are being put in place address 2819 SO10 [further details provided in hard copy report] phosphate issues.

David Wilson Homes object to Core Policy 28 in respect of Affordable Housing, which is contrary to PP3 Housing. David Wilson Homes object to Core 29 Meeting Housing Needs and Comments noted. The policies referenced are 2824 consider that the policy, as drafted, is inflexible. David Wilson Homes object to paragraph SO3 deemed appropriate and sound. 6.3.16 in respect of Lifetime Homes. Objection is raised to Core Policy 3 in respect of its lack of flexibilty. The same is true of Para 6.3.16 [further details provided in hard copy report]

The proposed core policy on Sustainable Construction and Low Carbon Energy requires development to meet the requirements of the full Objection to Code for Sustainable Homes or BREEAM Core Policy on standards in line with the national timetable for David Wilson Homes objects to Core Policy 26 in respect of Sustainable Contruction and Low Sustainable improvements to the energy performance of new 2825 Carbon Energy. The draft policy seeks to go beyond the nationally agreed position and Construction SO2 dwellings. The policy is considered to be justified timetable should be amended to reflect the national position. and Low as there is a pressing need to address climate Carbon change in Wiltshire. The policy includes flexibility Energy by stating that "in all cases the council will have regard to the impact of these requirements on the viability of development". Cross Comment No. Comments Officer Comments Issue Reference By The proposed core policy on Sustainable Construction and Low Carbon Energy requires development to meet the requirements of the full Objection to Code for Sustainable Homes or BREEAM Core Policy on standards in line with the national timetable for Mr & Mrs Archer objects to Core Policy 26 in respect of Sustainable Contruction and Low Sustainable improvements to the energy performance of new 2830 Carbon Energy. The draft policy is unsound seeks to go beyond the nationally agreed position Construction SO2 dwellings. The policy is considered to be justified and timetable should be amended to reflect the national position. and Low as there is a pressing need to address climate Carbon change in Wiltshire. The policy includes flexibility Energy by stating that "in all cases the council will have regard to the impact of these requirements on the viability of development".

Mr & Mrs Archer object to Core Policy 28 in respect of Affordable Housing, which is contrary to PP3 Housing. Mr & Mrs Archer object to Core 29 Meeting Housing Needs and consider that the 2831 policy, as drafted, is inflexible. Mr & Mrs Archer object to paragraph 6.3.16 in respect of Lifetime See comment 2824 SO3 Homes. Objection is raised to Core Policy 3 in respect of its lack of flexibilty. The same is true of Para 6.3.16 [further details provided in hard copy report]

Persimmon Homes welcome the Council's commitment to producing a Wiltshire-wide Core Strategy. However, the underlying strategy, the scale of housing and employment and the approach to the delivery of sustainable development, in the context of the Draft NPPF, the Government's 'Planning for Growth' statement and' the Localism Bill, need serious revision to address the overall soundness of the emerging Core Strategy and provide greater certainty and predictability for developers, other stakeholders and the public regarding the nature and distribution of growth in Wiltshire, taking account of its urban characteristics and settlement distribution and the needs and demands of its many rural settlements. It is clear that the planning issues facing Wiltshire are complex and should not be oversimplified or one factor given undue prominence at the expense of other important planning considerations. Persimmon Homes support the objections of the Home Builders Federation, in particular in respect of the Core Strategy's approach to out-commuting which is flawed. The Core Strategy, once the Regional Strategy has finally been abolished, will be the highest tier of locally prepared The Council will ensure that the Core Strategy is planning policy and its importance to achieving the effective delivery of development in Wiltshire compliant with the NPPF and the new Localism should be recognised. The Consultation Document falls short of what is needed, particularly Bill as and when these documents develop. The given the economic uncertainties and the social and demographic changes, including the maps within the Core Strategy are not meant to ageing population and declining household size, in Wiltshire during the remainder of the plan Number of 2832 act as proposal maps but simply figures similar to Q22 period. It is noted that the Core Strategy should look at least 15 years into the future from the issues a key diagram to make the document legible for date of adoption in accordance with PPS 12. As the plan may not be adopted until 2012 or the public. The comments regarding legal scrutiny 2013, at the earliest, the Council should seek to extend the plan period to March 2028, and general comments on the overall strategy are preferably March 2031 to look further ahead and maintain the 5 year quinquential periods, noted and will be taken into consideration. adopted in previous Structure and Local Plans and the Regional Strategies. By extending the plan period the Council will need to review its housing, employment and other requirements and refine its evidence base accordingly. Persimmon Homes note that the Pre-Submission Draft Core Strategy should also be accompanied by a new Proposals Map. The Proposals Map has legal status and to overlook this requirement may present problems for the Council and a future Planning Inspector in terms of legal challenges and the adoption process. Persimmon Homes note that the plan is unclear and would benefit from a policy or revision of an existing policy, akin to Structure Plan Policy DP4 or Table 4.1 of the Deposit Draft Regional Spatial Strategy, which clearly sets out, both by former district and by the newly defined Housing Market Areas, utilising the respective component Community Areas, the scale of development expected for the plan period (2006 - 26 or 2006 - 2031) and if possible the equivalent of employment land required. This table would also provide a clear framework for plan users to understand how much development is being identified through strategic allocations in the Core Strategy and Cross Comment No. Comments Officer Comments Issue Reference By how much is being deferred to Neighbourhood Plans or future Site Allocations DPD(s). The delivery of the as yet unidentified levels of development, during the plan period, at those areas preparing a Neighbourhood Plan or where a Site Allocations DPD for non-strategic allocations is a major concern and could potentially undermine the Core Strategy and the delivery of development during the plan period. As plans, including the Core Strategy, invariably under deliver development, it will be important for the Pre-Submission Draft to include a degree of contingency to allow for non-implementation and slippage. The dependency on existing commitments for the first half of the plan will inevitably mean the new development, covered by the Core Strategy, will be delivered in the second half of the plan period. Persimmon Homes have interests across Wiltshire and many of the neighbouring authorities. It is investing in the delivery of new homes, employment areas and infrastructure, through its current portfolio of sites and schemes. Persimmon Homes seek to continue to invest in Wiltshire and play a part in delivering the much needed development, sustainably, at the right place and time. The key to success will be a sound and deliverable Core Strategy for Wiltshire. Persimmon Homes are also working with key landowners, such as Mr Hocken at Warminster, stakeholder interests, such as the BRB (Residuary) Ltd at Westbury and with other developers in consortia, such as at East Melksham or North Chippenham. The company also seeks to deliver Persimmon and Charles Church developments at specific sites across Wiltshire. The maps within the Core Strategy are not meant Persimmon Homes note that Map 5.17 should be revised to show the national and international to act as proposal maps but simply figures similar 2843 wildlife designations. It is potentially misleading to show them all as County Wildlife Sites. (This Maps Q22 to a key diagram to make the document legible is also a general point which relates to the other maps in the Core Strategy) for the public. The proposed core policy on Sustainable Construction and Low Carbon Energy requires development to meet the requirements of the full Objection to Code for Sustainable Homes or BREEAM Core Policy on Persimmon Homes object to Core Policy 26 in respect of Sustainable Construction and Low standards in line with the national timetable for Sustainable Carbon Energy. The draft policy seeks to go beyond the nationally agreed position and improvements to the energy performance of new 2847 Construction SO2 timetable should be amended to reflect the national position. [further details provided in hard dwellings. The policy is considered to be justified and Low copy report] as there is a pressing need to address climate Carbon change in Wiltshire. The policy includes flexibility Energy by stating that "in all cases the council will have regard to the impact of these requirements on the viability of development".

Persimmon Homes object to Core Policy 28 in respect of Affordable Housing, which is contrary to PP3 Housing. Persimmon Homes object to Core 29 Meeting Housing Needs and consider 2848 that the policy, as drafted, is inflexible. Persimmon Homes object to paragraph 6.3.16 in respect See comment 2824 SO3 of Lifetime Homes. Objection is raised to Core Policy 3 in respect of its lack of flexibility. The same is true of Para 6.3.16 [further details provided in hard copy report]

Persimmon Homes object to Core Policy 39. A specific policy setting out a minimum density in Wiltshire is unnecessary and contrary to current and emerging national policy. The determination of an appropriate density for a given site should not be predetermined by a 'one size fits all' policy. It should be guided by design and constraint considerations together with the Comments noted. Consideration to changes of 2849 SO6 mix of housing required to meet housing needs and demands of the settlement. A policy the density policy will be given. specifying a minimum density is contrary to PPS3 Housing, where the Coalition Government dropped the indicative minimum density. Furthermore, it is noted that this position remains unchanged in the Draft NPPF. Cross Comment No. Comments Officer Comments Issue Reference By

Ashton Park objects to Core Policy 28 in respect of Affordable Housing, which is contrary to PP3 Housing. Ashton Park objects to Core 29 Meeting Housing Needs and consider that the 2855 policy, as drafted, is inflexible. Ashton Park objects to paragraph 6.3.16 in respect of Lifetime See comment 2824 SO3 Homes. Objection is raised to Core Policy 3 in respect of its lack of flexibility. The same is true of Para 6.3.16 [further details provided in hard copy report] The proposed core policy on Sustainable Construction and Low Carbon Energy requires development to meet the requirements of the full Objection to Code for Sustainable Homes or BREEAM Core Policy on standards in line with the national timetable for Ashton Park objects to Core Policy 26 in respect of Sustainable Construction and Low Carbon Sustainable improvements to the energy performance of new 2856 Energy. The draft policy seeks to go beyond the nationally agreed position and timetable should Construction SO2 dwellings. The policy is considered to be justified be amended to reflect the national position. and Low as there is a pressing need to address climate Carbon change in Wiltshire. The policy includes flexibility Energy by stating that "in all cases the council will have regard to the impact of these requirements on the viability of development".

Barratt Developments object to Core Policy 28 in respect of Affordable Housing, which is contrary to PP3 Housing. Barratt Developments object to Core 29 Meeting Housing Needs and 2860 consider that the policy, as drafted, is inflexible. Barratt Developments object to paragraph See comment 2824 SO3 6.3.16 in respect of Lifetime Homes. Objection is raised to Core Policy 3 in respect of its lack of flexibility. The same is true of Para 6.3.16 [further details provided in hard copy report]

The proposed core policy on Sustainable Construction and Low Carbon Energy requires development to meet the requirements of the full Objection to Code for Sustainable Homes or BREEAM Core Policy on standards in line with the national timetable for Barratt Developments objects to Core Policy 26 in respect of Sustainable Construction and Low Sustainable improvements to the energy performance of new 2861 Carbon Energy. The draft policy seeks to go beyond the nationally agreed position and Construction SO2 dwellings. The policy is considered to be justified timetable should be amended to reflect the national position. and Low as there is a pressing need to address climate Carbon change in Wiltshire. The policy includes flexibility Energy by stating that "in all cases the council will have regard to the impact of these requirements on the viability of development". Cross Comment No. Comments Officer Comments Issue Reference By CORE POLICY 28 - PROVIDING AFFORDABLE HOMES Crest and Redcliffe have already made comments about the level of affordable housing in respect of Core Policy 2 Delivery Strategy and how that level of affordable housing is not justified. Reference needs to be made to the advice in PPS3 Housing with regards the economic consideration of providing affordable housing. The Local Planning Authority must undertake a viability assessment to underpin and justify this level of affordable housing. There is no such report within the evidence base which accompanies the Core Strategy and it is unclear what the timescale is for its preparation. Of particular concern are the following factors: 4% affordable housing is not justified by any evidence base, viability or need The community are unlikely to be supportive of that level of affordable housing It is not reflective of values, sales rates, lending criteria and the current market in Chippenham, Wiltshire, the South West of England, the UK, the world, the galaxy or the universe. It exceeds the requirements of RSS, which was written in a good economic climate when grant funding was available. This is a poor market with no grant and is unlikely to Comments noted. The submission strategy will be change during the plan period. The balance between affordable housing and housing that is tested for viability. Consideration will be given 2867 SO3 affordable is complex. That proportion of affordable housing will necessitate market demand for with regards to changing the lifetime homes, a much higher overall housing figure in order to meet the needs of local people who do not design and density policies. qualify for social housing (i.e. most of them) A viability clause is required in the policy for when it cannot be delivered That scale of affordable housing will limit the availability of finance for S16 and infrastructure significantly Crest and Redcliffe consider that the policy is fundamentally flawed as it is not underpinned by a Viability Assessment or a Strategic Housing market Assessment. Recommendation Objections are raised to this policy until a financial viability assessment has been undertaken to underpin the policy and the figure is revised downward. CORE POLICY 3 - LIFETIME HOMES STANDARDS Crest and Redcliffe object to this policy which requires al1 new residential development to accord with Lifetime Homes Standards. Whilst this may well be an admirable objective there is no justification within national or local policy for all new residential development to achieve Lifetime Homes Standards. If anything this should be an aspiration not a requirement. Recommendation Delete the requirement that all new homes achieve Lifetime Homes Standards. CORE POLICY 37 - ENSURING HIGH QUALITY DESIGN AND PLACE SHAPING Crest and Redcliffe are dedicated to excellence in design and construction in order to achieve high quality communities and to customer service. Their schemes are formulated to generate a distinct community spirit by the incorporation of key features. These include distinctive residential area with their own character and identify and generous areas of open space and facilities including schools, shops and recreation facilities. All of these features would be incorporated with n the South Chippenham expansion as outlined in the Vision Statement. Crest and Redcliffe have a number of issues with regards this policy as follows: i) Usability and Amenities Objections are made to the production of a Design SPD which would set out specific internal space standards for new residential development. It is considered that there is no justification for the Council to suggest internal space standards. The private sector is well experienced in not only developing Comments regarding specific development new housing but knowing exactly what its customers require. Accordingly, there is no need or proposals noted. Objections noted regarding justification for Local Planning Authority to suggest internal space standards. ii) Design 2869 internal space standards. Consideration will be SO6 Standards Objections have already been made in respect of Core Policy 36 to the requirement given to changes to both the building for life to make all new residential development, Building for Life (the other policy was Lifetime Homes reference within policy and minimum density. but we need to object to both) compliant. There is no justification in national planning policy for this approach. It should therefore be deleted. Recommendation Delete the reference to internal space standards and the making all new residential development Building for Life Compliant. CORE POLICY 39 - HOUSING DENSITY Crest and Redcliffe object to this policy and in particular the requirement for residential development to achieve a minimum net density of 3 dph. PPS3 Housing (June 211) has deleted the requirement to achieve a minimum density on new housing sites. In line with good planning and Core Policy 37, the density of new residential development should be arrived at as a result of an identification of the constraints and opportunities a well as the considerations of the development proposed and the community envisaged. Development should be design led and in keeping with the character of the area and the vision for the community. Design should inform density, not the other way around. Cross Comment No. Comments Officer Comments Issue Reference By There is no requirement for a minimum density requirement within this policy and it should be deleted. Recommendation Delete reference to achieving a minimum net density of 3 dph.

Support for Core Policy 26: Sustainable Construction and Low-Carbon Energy The project team fully Support welcomed. The council intends to Core Policy on support the approaches and requirements identified in Core Policy 26. In addition to the prepare further guidance to assist with the Sustainable measures summarised in CP26 we suggest that the Council should require all developments to 2873 implementation of the policy, and reference to the Construction SO2 adopt the Soft Landings Protocol developed by BSRIA. This will help to ensure that the gap is Soft Landings Protocol may be appropriate in that and Low closed between the design theory/intent (and Part L Building Regulations requirements) and future guidance document. Carbon actual energy performance of low/zero carbon buildings inuse. Energy.

Core Policy 28 - Providing affordable homes The inclusion of a policy on affordable housing within the Core Strategy needs to be based on an evidence of need, provided within a Strategic Housing Market Assessment, and an assessment of the viability of residential development in order to accord with national policies in PPS3: Housing. The Council has not published an SHMA and we understand that while an SHMA is being prepared, this has not been completed. The Council has not published a Viability Study. It thus seems premature for the Council to be consulting on a proposed target and thresholds for affordable housing provision. Notwithstanding this issue, we consider that Core Policy 28 should be amended to support housing delivery and to allow the tenure mix of housing development schemes to respond to local needs. The last few years have demonstrated that housing market circumstances and the viability of residential development can change rapidly. Net housing completions in Wiltshire in 29-1 were over 2% down on average levels before 28. An affordable housing policy needs to be Comments noted. The policies contained within flexible to respond to these changes in these circumstances to maintain delivery. Moreover, the the core strategy will be tested for viability. The collective impact of policies within the plan on the viability of development needs to be core policy is flexible to take account of viability 2874 SO3 considered, including contributions to infrastructure and policies relating to sustainability considerations. The strategy also includes a construction and low carbon energy. This point is clearly made in the draft National Planning flexible policy approach in relation to the type and Policy Framework which sets out in paragraph 41 that: "Local planning authorities, parishes and mix of new homes. neighbourhood forums should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the development plan at serious risk, and should facilitate development throughout the economic cycle." A viability study which considers the collective impact of policies within the Plan needs to be undertaken. In the absence of this it is inappropriate to comment further on the percentage of affordable housing sought, or for the Council to set out proposals. It is also important that the mix of housing brought forward through new development schemes responds to and meets local housing need and demand, not just that assessed at a strategic level, county-wide. The Consultation Document makes this point in Cross Comment No. Comments Officer Comments Issue Reference By paragraph 6.3.2 stating that the right homes in the right place at the right time are required to deliver balanced communities and in Core Policy 28 in regard to tenure. Core Policy 28 should provide greater flexibility to tailor housing provision to local needs. Against this context, we consider that 1. Core Policy 28 should be reviewed in light of evidence of housing need/demand from the SHMA, and an assessment of development viability which takes account of other policies in the Plan, including Core Policy 26 and infrastructure requirements. 2. That the wording of Core Policy 28 should be amended to state that affordable housing of up to xx% will be expected on sites of 15 or more dwellings, and a requirement of xx% net on sites of 5 to 14 dwellings, subject to evidence of local need . 3. An additional sentence should be introduced into Core Policy 28 relating to the level of provision, which should support an open book approach to considering the viability of development schemes, taking account of the cumulative impacts of local and national standards and policies, and any abnormal costs related to the development scheme. We consider that this latter point is essential to be consistent with national policy and support housing delivery. Core Policy 29 - Meeting housing needs Core Policy 29 is supported in terms of its ambition to relate housing mix to the needs of local communities. However it is considered that the wording is considered further. The policy should have regard not just to local housing need but to demand. The mix of housing in developments should reflects local need and demand, as well as having regard to the needs of Wiltshire. The wording of the policy should be amended as follows: New housing must be well designed to address local housing need and demand incorporating a range of different types, tenures and sizes of housing to create mixed communities. The size and type of housing in developments should have regard to the needs of Wiltshire as set out in the Strategic Housing Market Assessments. Core Policy 3 - Lifetime homes standards It is accepted that the underlying objectives of Lifetime Homes Standards are laudable, and that many of the criteria can be readily incorporated into the design of residential development. However, the requirement under Policy CP 3 for all residential development to be compliant with Lifetime Homes standards is considered to be unsound . Compliance with all 16 of the Lifetime Homes criteria is unduly prescriptive, and will create practical implementation consequences that in turn will adversely affect the viability and deliverability of housing development. Paragraph 41 of the consultation draft NPPF requires LPAs to assess the cumulative effects of local policies and national standards. There is no evidence that such a process has been undertaken in respect of Lifetime Homes in the Draft Core Strategy. Examples of the practical consequences of the rigid application of Lifetime Homes Standards are summarised below: Space requirements: for example, in three bedroom dwellings, the increased ground floor WC width and increased circulation space effectively either reduces the lounge width by 75mm or increases the overall floor area by at least 1% which will create a proportionate increase in build cost. We doubt very much if the increased circulation space and WC size, and other requirements such as winder mechanisms on windows, will be seen as necessary, desirable, or good value-for-money by the average home purchaser/occupier. Density: the requirement to place the living area at entrance level effectively rules out 3 or 4 storey houses, where the living space is almost always on the first floor level. This conflicts with increasing density requirements, and with the Code for Sustainable Homes, which awards maximum points for developments incorporating 3 and 4 storey dwellings, and will have a major impact on design in urban areas where such a house style is typical. Car Parking: the increased car parking space requirement will also have a negative effect on density and effective use of land. General needs: evidence from the RSL sector suggests that despite having invested in the requirements of Lifetime Homes very few homes, if any, have undergone the adaptations made theoretically possible by Lifetime Homes i.e. through the floor lifts, hoists, ground floor showers etc. When occupiers get to the point of needing to make the adaptations they generally move to a more appropriately designed homes rather than settle for a make-shift Lifetime Homes conversion. This again questions the value for money of incorporating the requirements wholesale in all new residential development, and suggests that the requirements should be confined to a fixed percentage of properties. Design: forcing designers to follow a specific set of design rules for all properties will inevitably have an impact on the design. For example all properties will be required to have a canopy over the Cross Comment No. Comments Officer Comments Issue Reference By entrance door, even where this is not typical of the local style. It is recommended that the Policy CP 3 is deleted , and that the application of Lifetime Homes standards is negotiated on a case by case basis, where an appropriate percentage of new dwellings could be agreed as being Lifetime Homes compliant.

Bath & North East Somerset Council comments on Wiltshire Core Strategy Consultation document published June 211 Introduction The western part of Wiltshire (the former District Council of West Wiltshire) is located within the West of England Housing Market Area (HMA), and parts of western Wiltshire are also within the travel to work area of Bath. Therefore, the links with Bath are well established in that some towns and villages within western Wiltshire supply part of Bath's labour force, whilst the residents of western Wiltshire look to both Bath and Bristol for higher-level services and employment. Generally the emerging Wiltshire Core Strategy is welcomed by the Council, in particular the overall strategy to focus employment-led growth at Trowbridge, Chippenham and Salisbury and the Market Towns in order to achieve a greater level of self containment and provide the jobs locally that Wiltshire's communities need. The Council welcomes the recognition in the Core Strategy that previous growth within Wiltshire hasn't always been delivered in a proportionate manner whereby housing has been delivered in settlements where there are insufficient employment opportunities. This has lead inevitably to out-commuting, not only to Bath, but also to other parts of Wiltshire, Swindon and to the South East. The approach of Wiltshire to focus on an employment led strategy is therefore appropriate in order to improve the self-containment of the settlements in West Wiltshire and stabilising and, in the longer term, reducing the current level of out-commuting. Overall level of development and phasing The Secretary of State's Proposed Changes to the RSS were published in 28 Overall 2875 which suggested an increase in the amount of housing that Wiltshire Council should provide Support Noted. Q22 Strategy during the period to 226 from 34,5 homes required in the draft RSS to 44,4 required in the Proposed Changes. ‘Wiltshire 226' was also based on this higher figure. This version of the Wiltshire Core Strategy has reduced the housing requirement to around 37,, which is less than the Proposed Changes, but more than the draft RSS requirement. This Council believes the approach taken by Wiltshire to critically appraise and challenge the RSS figures in light of new and more up-to-date evidence is the correct one, and validates Bath and North East Somerset's (B&NES) own approach in setting out a locally determined housing number in the B&NES draft Core Strategy. The Wiltshire Core Strategy approach of phasing housing development to align with new employment provision is also supported and aligned with the approach in the B&NES draft Core Strategy. Commuter flows and development in West Wiltshire Wiltshire has strong links with the surrounding large urban centres including Bath and as a result it currently suffers from high levels of out-commuting for work and loss of expenditure locally through people travelling for shopping and leisure purposes to these larger urban areas. The Wiltshire Core Strategy emphasis is on job growth which will support the aim of reducing the need to travel by providing job opportunities locally. Much of Wiltshire has lower residence based self containment (66% in the case of West Wilts) than B&NES (7%), although frequently a higher level of workplace based self containment (76% for West Wilts). Notwithstanding the importance of settlements such as Trowbridge, this is to be expected in an area which is Cross Comment No. Comments Officer Comments Issue Reference By somewhat less dominated by a major urban centre and inevitably with a narrower choice of employment opportunities. The importance of sub regional co-operation between both authorities is acknowledged both in the Wiltshire Core Strategy and B&NES draft Core Strategy. However, it has to be recognised that in an area such as the Bath Travel to Work Area, with many alternative locations for both employment and residence, people will naturally exercise these options, and some will always choose to commute irrespective of housing provision close to their place of work. The B&NES draft Core Strategy aims to stabilise these commuting patterns, with the strategy for Bath in the draft Core Strategy to enable a shift in the level of self-containment from 7% to nearer 8%. One approach that B&NES would support is the improvement of the range and quality of employment opportunities in West Wiltshire, which it is noted is a key objective of the Wiltshire Core Strategy. The Council would wish to be assured that these employment allocations are deliverable as housing delivery without investment in job creation will increase unsustainable out-commuting, as acknowledged in the Sustainability Appraisal. The strategy for Trowbridge is to stabilise the level of commuting to other centres (including Bath) which is in line with the B&NES draft Core Strategy. 6, dwellings are proposed in the Core Strategy as opposed to 5,92 in ‘Wiltshire 226'. Whilst these figures are high and in line with the RSS Proposed Changes, B&NES is satisfied that the intention to provide leisure/cultural/shopping facilities in the town will help to reduce reliance on and the need to travel to Bath. The focus on job growth/improving skills (within significant employment allocations) at Trowbridge is also supported. The housing figure for Chippenham has been reduced from 5,74 in ‘Wiltshire 226' to 4,5 to ensure that it only meets its own needs and improves its self containment. The Council support this in terms of limiting in-commuting to Bath so long as sufficient housing in the wider market area overall is being provided. It is noted that the Sustainability Appraisal has highlighted that, when considering existing employment sites, "Option 1 could lead to loss of many smaller employment sites throughout Wiltshire which would mean people having to travel further to seek work. There would not be the same amount of employment opportunities, particularly in some of the smaller towns, significantly increasing the need to travel for jobs elsewhere in the county or further afield. This would exacerbate current problems of out-commuting to towns along the M4 corridor such as Bristol, Bath and Swindon". Infrastructure Provision Given the strong functional relationship between Bath and Wiltshire towns it is vital that transport infrastructure is planned and delivered in consultation with neighbouring authorities. Continuation of cross boundary working between B&NES and Wiltshire Councils where circumstances permit is a priority. The Wiltshire Core Strategy refers to improving sustainable transport links to Bath, which is in line with the B&NES draft Core Strategy and Transport Strategy for the city and fully supported. Reference should be made in the Wiltshire Core Strategy to key items of transport infrastructure such as the electrification of the Great Western Mainline railway which will improve the ease of access to and attractiveness of rail travel to and from Bath. B&NES Council looks forward to working with Wiltshire Council on our respective Infrastructure Delivery Plans. This includes Green Infrastructure; the B&NES Strategic GI network and links between both areas should be acknowledged in the Wiltshire Core Strategy and GI strategy. Previous comments on Wiltshire Core Strategy It was noted in the previous iteration of the Wiltshire Core Strategy that the village of Colerne was proposed as having capacity to accommodate modest development to help meet local housing need. B&NES Council expressed concern at that time about this proposal due to the prospect of increased traffic travelling into Batheaston, particularly HGVs, and the fact that problems have been arising on Bannerdown Road as a result of HGV's accessing development at Colerne Airfield, with no alternative, viable routes. It is noted that in this version of the Wiltshire Core Strategy the Corsham Community Area, of which Colerne is a part, 1,2 new homes are planned, with the majority (1,5) at Corsham. Therefore, any development at Colerne is likely to be modest. Nevertheless, we maintain our concern that any expansion of development could give rise to increased traffic in this locality. ‘Wiltshire 226' also proposed development at Bradford-on-Avon and acknowledged that the town had a high level of out-commuting, effectively functioning as a dormitory settlement to Bath. B&NES Council previously raised concerns to any development that increased the amount of traffic travelling into Bath from Cross Comment No. Comments Officer Comments Issue Reference By Bradford-on-Avon. It is clarified in this version of the Wiltshire Core Strategy that Bradford-on- Avon is not identified as a strategic location for employment. The high level of out-commuting indicates that development of business and employment should be encouraged to meet local needs. This additional provision will help improve the balance between housing and employment growth in the town, and offers the opportunity to improve self containment. Whilst the Council can support this approach, which is in-line with the B&NES draft Core Strategy, our previous concerns that Bradford-on-Avon should avoid the type of employment development that would be likely to give rise to increased traffic movements through Bath, i.e. travelling between Bradford-on-Avon and Bristol, and in particular HGV movements along this route are re-iterated.

I the undersigned [Member of the public] have studied Wiltshire Council's draft Core Strategy and have concluded that it does not represent a coherent plan for the future of West and North Wiltshire to 226 and beyond. Last year I were led to believe that the abolition of regional allocations for building new homes in the county would allow the public to decide how much development they wanted in Wiltshire and where they wanted it. Today I find that the massive housing estates and retail parks have not shrunk back from the green field sites where the developers would like to build them. Twenty thousand new homes and something like a square kilometre of industrial estates are planned for North and West Wilts by 226 - homes and jobs for another 5, people. I question fundamentally whether this model of expansion can bring the The Core Strategy has a number of policies that economic growth the council expects, while also meeting the needs of existing communities in aims to address a number of the issues raised in an area where transport, education and health services are already struggling to meet demand. this response. Core Policy (CP) 6 details a plan Clearly, past planning policies have not worked, yet the Council's Core Strategy is proposing to regenerate Trowbridge town centre and CPs more of the same: More decline of town centres More characterless car-based suburbia More 42 - 48 detail a comprehensive transport plan for traffic, congestion, noise and pollution in both towns and villages More damage to the natural development and strategies across Wiltshire. The environment and loss of agricultural land More overloaded services Rather than reproduce housing and employment being planned for is these outdated policies in the blueprint for the next 15 years, I ask the council to think again based on the most up-to-date evidence available and give me: 1. An overall reduction in the housing numbers it has proposed for West and in line with Government advice as detailed in North Wiltshire, seizing the opportunity offered by the scrapping of regional allocations and topic paper 17. While it is recognised that a fulfilling the promise of a new 'localism' in planning policy; 2. A more honest consultation that Overall 2881 number of Greenfield sites are being planned for Q22 provides real data and maps on the traffic implications of proposed growth in our area; 3. Much Strategy mitigation and measures to ensure continuing stronger policies to ensure that people will have real opportunities to switch from driving to protection of the environment are being taken to walking, cycling and travelling by bus or train - a key objective of the Wiltshire Community Plan; ensure that sensitive areas are not damaged by 4. A better and more informed appraisal of real needs for new jobs and new homes; the development. New maps will be produced for the relationship between these needs and the skills wanted to develop and attract in coming years; next draft of the Core Strategy. Finally it should a more direct way to meet the urgent need for affordable homes in towns and villages; 5. The be recognised that the Core Strategy does carry channelling of developer funds away from building more roads and towards developing and legal weight and as such needs to make sure it improving town centres, creating 'green infrastructure' and supporting better public transport; 6. can stand up to scrutiny, however every effort is The clear prioritisation of Trowbridge and other town centres for office development to bring made to make it legible for non-planning vitality back to central areas; 7. Fewer new employment areas on the fringe of towns -less 'tin professionals. shed land' in the open countryside; support for rural employment, farm-based enterprises, local food and working villages; 8. A sustainability appraisal that genuinely examines the environmental consequences of hot-housing Western Wiltshire, and looks at other options for development in the coming decades of climate change, peak oil, and shortages of food and water; 9. A Core Strategy that is understandable to the ordinary person rather than hiding its objectives in planning jargon and evasive verbiage; 1. The publication of accurate maps to show the proposed locations of housing and employment areas and the roads and other strategic infrastructure and services that the council is planning to provide for them. I consider that the present draft of the Wiltshire Core strategy is not fit for purpose. I ask the Council to Cross Comment No. Comments Officer Comments Issue Reference By think again.

Last year I was led to believe that the abolition of regional allocations for building new homes in the county would allow us to decide how much development we wanted in Wiltshire and where we wanted it. Today we find that the massive housing estates and retail parks have not shrunk back from the green field sites where the developers would like to build them. Twenty thousand new homes and something like a square kilometre of industrial estates are planned for North and West Wilts by 226 - homes and jobs for another 5, people. I question fundamentally The Core Strategy has a number of policies that whether this model of expansion can bring the economic growth the council expects, while also aims to address a number of the issues raised in meeting the needs of existing communities in an area where transport, education and health this response. Core Policy (CP) 6 details a plan services are already struggling to meet demand. Clearly, past planning policies have not to regenerate Trowbridge town centre and CPs worked, yet the Council's Core Strategy is proposing more of the same: More decline of town 42 - 48 detail a comprehensive transport plan for centres More characterless car-based suburbia More traffic, congestion, noise and pollution in development and strategies across Wiltshire. The both towns and villages More damage to the natural environment and loss of agricultural land housing and employment being planned for is More overloaded services Rather than reproduce these outdated policies in the blueprint for the based on the most up-to-date evidence available next 15 years, I ask the council to think again and give us: 1. An overall reduction in the in line with Government advice as detailed in housing numbers it has proposed for West and North Wiltshire, seizing the opportunity offered topic paper 17. While it is recognised that a by the scrapping of regional allocations and fulfilling the promise of a new 'localism' in planning Overall 2884 number of Greenfield sites are being planned for Q22 policy; 2. A more honest consultation that provides real data and maps on the traffic Strategy mitigation and measures to ensure continuing implications of proposed growth in our area; 3. Much stronger policies to ensure that people will protection of the environment are being taken to have real opportunities to switch from driving to walking, cycling and travelling by bus or train - ensure that sensitive areas are not damaged by a key objective of the Wiltshire Community Plan; 4. A better and more informed appraisal of our development. New maps will be produced for the real needs for new jobs and new homes; the relationship between these needs and the skills next draft of the Core Strategy. Finally it should we want to develop and attract in coming years; a more direct way to meet the urgent need for be recognised that the Core Strategy does carry affordable homes in towns and villages; 5. The channelling of developer funds away from legal weight and as such needs to make sure it building more roads and towards developing and improving town centres, creating 'green can stand up to scrutiny, however every effort is infrastructure' and supporting better public transport; 6. The clear prioritisation of Trowbridge made to make it legible for non-planning and other town centres for office development to bring vitality back to central areas; 7. Fewer professionals. new employment areas on the fringe of towns -less 'tin shed land' in the open countryside; support for rural employment, farm-based enterprises, local food and working villages; 8. A sustainability appraisal that genuinely examines the environmental consequences of hot- housing Western Wiltshire, and looks at other options for development in the coming decades of climate change, peak oil, and shortages of food and water; 9. A Core Strategy that is understandable to the ordinary person rather than hiding its objectives in planning jargon and Cross Comment No. Comments Officer Comments Issue Reference By evasive verbiage; 1. The publication of accurate maps to show the proposed locations of housing and employment areas and the roads and other strategic infrastructure and services that the council is planning to provide for them. I consider that the present draft of the Wiltshire Core strategy is not fit for purpose. I ask the Council to think again. Finally, Could I ask that the village of Hilperton be catagorised as a large village, rather than being subsumed with in Trowbridge town.

I am writing on behalf of North Wiltshire Friends of the Earth to submit our comments upon the draft Core Strategy of Wiltshire Council 26 to 226. We advise that we have signed an Open Letter in conjunction with other organisations and persons to Wiltshire Council on this matter, copy appended. We advise that the comments submitted here, dated 31 st July 211, are in addition to the Open Letter. Application of Democracy. We note that with the abolition of the South West Regional Assembly, the responsibility for strategic planning matters has been devolved down to Individual counties/unitary authorities and, in our case, Wiltshire Council. Hence this present draft Core Strategy, and the opportunity for the people of the county to determine their own strategic planning policies for the period 26 to 226. We have noted the following about the application of the public consultation process: 1. It appears that exactly the The Core Strategy has used updated population same population growth statistics and forecasts have been used by Wiltshire Council as those projections issues by the office of national used by the Regional Assembly and, given that the need for new housing, new employment statistics, this is set out in topic paper 17 which provision and new infrastructure is determined by forecasted population growth, the result is details how these projections have been that exactly the same development model has been advanced by Wiltshire Council as was converted into housing targets. The apparent advanced by the Regional Assembly. Thus there is no originality in the draft Wiltshire Core similarities between the South West RSS and the Strategy, no attempt to think anew the principles and objectives of strategic development, and Core Strategy can be attributed to them both Overall 2885 Q22 the people of the county are simply being presented is essence with a carbon copy of the being prepared in the same national planning Strategy former Regional Assembly plan. From our point of view, this is a missed opportunity to think context. Where possible a number of Councillors again about what the county needs in terms of development over the 2 year period, and a are often present at public meetings, nevertheless failure to re-examine the principles and objectives of such development. It is therefore a failed the onus is on officers to demonstrate to document in the sense that it has not re-examined or re-opened the debate on the principles Councillors how public consultation has been and objectives of development, and we recommend that the present document be withdrawn to carried out when they approve the plans at permit a recommencement of the process whereby a genuine determination of planning council meetings. development principles and objectives for the county is undertaken. 2. We have noted that in the public meetings, organised by the Council for the explanation of the draft Core Strategy, the presentation of the Strategy was undertaken entirely by officers of the Council, and not by elected members of the Council (other than an elected member serving as a chair for the meeting). Given that the decision to adopt the draft Core Strategy was made by the elected members of the Council, we believe that these public meetings should have been led and addressed by the elected members of the Council, with the officers simply on hand for technical advice. This did not occur. We are unaware of any elected member attempting an explanation to the public of the political character and options in the decision-making process relating to the Cross Comment No. Comments Officer Comments Issue Reference By draft Core Strategy. As a result, we believe that the presentation of Core Strategy at public meetings organised by the Council had a substantial democratic deficit and this deficit was, in our opinion, prejudicial to the public being able to understand the full range of options available for the determination of the principles and objectives of the Core Strategy. Accordingly, we recommend that the public consultation process be reconstituted and re-run on a full and proper democratic basis, and the present draft Core Strategy be withdrawn to enable this to occur. 3. During the public meetings on the draft Core Strategy organised by the Council, the public were advised by the officers that Town Councils may draw up their own Development Plans for the period to 226 with reference to their own locality, and that these Development Plans would be fed into the formulation of the Core Strategy. However in the same breath, officers also advised that if a Town Council were to come up with a development model and plan that did not substantially reflect the development model and plan of the Wiltshire Core Strategy, then it would be over-ruled because the county-based Development Plan trumped the local-based Development Plan. This, the public were informed, would be the case despite the present Westminster Parliament's Localism Act. This means that if a Town Council were to spend time, effort and resources developing a Development Plan that reflected the priorities of the local people, but was in conflict with the county-based Development Plan (draft Core Strategy), then the time, effort and resources given by the Town Council to the formulation of such a Development Plant would be entirely wasted. Hence, this advice from officers was a strong disincentive to Town Councils to come forward with Development Plans which did anything other than substantially reflect the principles and objectives of the county-based draft Core Strategy. In the case of Chippenham Town Council, the Town Council has conducted a survey of public opinion which has expressed strongly the belief that development on the periphery of the town is not favoured (e.g. against the development of a new eastern bypass/development at the southern end of the existing bypass), and that the type of development which is favoured is maintaining the town at approximately its current size, with regeneration of the town centre both economically and in terms of its retail and recreational facilities, and that development should concentrate on enhancing the environment bordering the river's course through the town rather than on developing agricultural and other open land on the edge of the town. In our opinion, it is clear that the development model favoured by the public in Chippenham has not been advanced by the Town Council because such a local Development Plan would conflict with the county-based Development Plan (draft Core Strategy). As a result, the documented and genuine aspirations of the public in Chippenham for a different form of development from that articulated by the county-based plan has been thwarted by the Wiltshire draft Core Strategy. Hence, we perceive a clear democratic deficit in the formulation of the county-based draft Core Strategy, and we recommend the withdrawal of the draft Core Strategy to permit local development plans to be submitted by Town Councils throughout the county, and that the draft Core Strategy then be re-written so as to proceed from the bottom upwards in terms of the formulation of its principles and objectives, rather than impose these principles and objectives from the centre downwards as is currently the case. Cross Comment No. Comments Officer Comments Issue Reference By Population Statistics. The draft Core Strategy is based on forecasts of growth in the population of the county for the period 26 to 226, and argues that development must meet the character and thus the needs of this population growth. We have examined these population growth statistics, and have found them to be tabulated and recorded in such a manner that the ordinary person (member of the public) has no way of understanding them, unless this person has a degree in statistics and access to the statistical assumptions upon which the forecast is made. In our opinion, this is entirely unacceptable. It conflicts wholly with the principle that the evidence base on which the draft Core Strategy is founded should be transparent, accessible and easily understood. The draft Core Strategy should state clearly and simply how forecasted population growth is calculated, recording growth in the following areas: Growth or decline in the population due to the difference in the birth rate and the death rate - in other words, "natural" population variation. The difference between inward and outward migration in the Topic paper 17 sets out the way population county, supported by a clear factual analysis of actual historical trends relating and the factors statistics have been used to arrive at housing determining those trends. Clear analysis of the demography of the county's population to show projections . Many of the factors referred to in the whether there is any feature in its age structure which requires a certain development model or response are taken into account as part of the Evidence 2888 need to be planned for e.g. a population that may be either weighted at the younger end Q22 population statistics provided by National Office of Base (proportionally more people in the 2-3 years age range than hitherto) or at the older end Statistics. These have been summarised in the (proportionally more people at the 65 to 85 age range than hitherto). Clear analysis of any most accessible format possible but due to their social character in the population requiring particular attention in the development model, very nature are detailed statistical calculations. supported by facts and figures e.g. changes in the divorce rate leading to single parent households or immigration from overseas. The draft Core Strategy does not provide a clear, transparent and readily understandable record of forecasted population trends. It does not provide facts and figures in a form that can be easily understood, or easily checked. This deficiency therefore means that the public is unable to determine whether the basis on which the whole architecture of the draft Core Strategy's development model is constructed is genuinely sound, or is unreasonable and unsound. In our opinion, this is a serious weakness and deficiency, and essentially invalidates the draft Core Strategy. As a result, we recommend the draft Core strategy be withdrawn to enable a clear and transparent statement of the population growth/decline forecast to be recorded, and that this re-statement of this forecast in population growth/decline be also subjected to analysis by an independent third party in order to ensure that the public may have confidence in its accuracy. Energy and Climate Change. Central to the Core Strategy must be the means of generation of energy and its use. There are legal obligations in this area. By 25 the United Kingdom as a whole must reduce its greenhouse gas emissions (principally, carbon dioxide emissions from fossil fuel use) by 8% based on 199 levels, and establish carbon budgets and strategies to accomplish this, ref. UK Climate Change Act 28. We note that the draft Core Strategy Policy Comments noted. The proposed core strategy Paper on Climate Change states: 1.5 Recommended policy approaches: 1.5.1 This paper, in seeks to support sustainable construction and low part informed by the WSEPS, makes a series of recommendations for developing policies for carbon energy through core policies 26 and 27 of inclusion in the Wiltshire Core Strategy to address specific aspects of climate change. Policies the June 2011 consultation document. It is are proposed which address six identified issues. These are: to ensure new development is considered that a balanced approach is resilient to likely future rises in temperatures resulting from climate change to set Wiltshire wide appropriate, which seeks to achieve significant sustainable construction standards for new development o to improve the energy performance improvements in sustainability without 2891 of the existing Wiltshire Building stock (where permitted development rights do not apply) to SO2 jeopardising the delivery of appropriate maximise opportunities to deliver decentralised, low-carbon and renewable energy in new development. The proposed core policy 27 would development to encourage the development of large scale standalone renewable energy apply to all types of renewable energy schemes in Wiltshire to support the delivery of a district low-carbon or renewable energy/ heat installations, including wind turbines. The June network in Trowbridge Town Centre. Ref. 2011 consultation document also includes the http://www.wiltshire.gov.uk/wiltshire_core_strategy_draft_ topic_paper_1_- proposed core policy 42 which seeks to promote _climate_change_june_211_.pdf We also note from the same source: 1.3.12 The WSEPS sustainable transport. [Wiltshire Sustainable Energy Planning Study, Cameo 211] has concluded that there is potential for almost 3 % of the projected electricity demand in 22 and over 9 % of the projected heat demand in 22, to be derived from renewables in Wiltshire. The report suggests that an installed capacity of almost 367 MW would be needed to meet this level of electricity to be supplied from renewables. and o By far the largest component (94 %) of existing renewable Cross Comment No. Comments Officer Comments Issue Reference By energy capacity in Wiltshire is derived from landfill gas which will reduce in the future as the amount of waste sent to landfill is reduced; and o Wiltshire contributes the second lowest level of renewable electricity of all authority areas in the South West (8.9 %) [emphasis in the original] and makes the lowest contribution of renewable heat (4 %). We observe that for Wiltshire, as a community, to be meeting its UK Climate Change Act obligations it has, effectively, to be reducing its carbon emission by 2% per annum (21 to 25 = 4 years, 2% per annum x 4 = 8% reduction by 25). We observe that in the draft Core Strategy there is no strategic plan which explains how this annual practical (non-legal) requirement of2% reduction in greenhouse gas emissions will accomplished. We also observe that Wiltshire, as a county, has virtually no wind turbine installations; and, that there is political resistance to their installation. We observe that the Wiltshire Sustainable Energy Planning Study, Camco 211 expects that at least half of the 3% potential for the generation of electricity from renewable sources by 22 will be sourced from large wind turbines (ref. Camco WSEPS, page 92.). We further observe, that we can see no evidence in the draft Core Strategy as to how this projection relating to the installation of large wind turbines will be accomplished. Indeed, this prediction as to the sourcing of renewable energy from large wind turbines looks unrealistic at the present time. We note that currently the source of renewable energy in the county is almost exclusively landfill gas, and that this "resource" is expected to decline in the next 4 years as landfill is phased out. As a result, we do not find the draft Core Strategy credible in the matter of its strategic plan to reduce greenhouse gas emissions by 8% by 25 (circa. 3% by 226). In short, we can see no evidence of such a plan. And, we do not find the draft Core Strategy credible in the matter of how it is to generate carbon neutral energy in order to achieve 3% substitution by 226. In short, its current source of such energy - landfill gas - will decline in this period; and, there is politcal resistance to the installation of large wind turbines which has precluded any planning for this provision in the draft Core Strategy. In order to address the serious deficiencies and weakness in the draft Core Strategy in the area of energy and climate change, we propose the following: 1. Every community of 2,5 or more people in the county should be largely self-sufficient in energy generation by 25. 2. This self-sufficiency should be attained largely by a mixture of electricity generation from wind power and pholt-voltaic solar panels, with biomass also being employed where it can be demonstrated as being neither harmful to agricultural production nor the natural environment. We observe that large wind turbines can be intrusive in a landscape when their number rises above two, perhaps three, in the same site. We also observe that the opportunity to install photovlotaic cells in large banks can be achieved unobtrusively in such locations as the flat roofs of buildings on industrial estates. (Note: indeed in Germany photo-voltaic installations are now so extensive that during daytime they generate the equivalent of four nuclear power stations). We therefore propose that large wind turbines can be installed throughout the county if they are located in ones or twos in relation to settlements of25 persons or more. Thus, each community of 25 people can install a single large wind turbine to assist in meetings its requirement to become energy (electricity) self-sufficient, and this can be supplemented by photo-voltaic panels installed on the roofs of houses and industrial/commercial premises in the area, and where communities are larger than 25 persons large wind turbines can be sited strategically in ones or twos in greater number in order to meet the larger proportionate need, again supplemented by photo-voltaic installations. We believe that this proposal implements the requirement and opportunity set out in the Wiltshire Sustainable Energy Planning Study and, most importantly achieves a conversion to renewable energy that is both unobtrusive in landscape terms and is compatible with current political objections. In short, it is a strategy which enables communities through the county to become both energy self-reliant and compliant with the reduction in greenhouse gas emissions by 25 (UK Climate Change Act 28). In respect of transport, we believe that the conversion of transport fuels from petrol and diesel to electricity and hydrogen needs to be undertaken and planned for, assisted of course by a reduction in the need to travel (note: our policy for the regeneration of Wiltshire town centres) and the greater provision of public transport. Therefore we recommend that the draft Core Strategy be withdrawn to enable the development of both strategies and policies which will ensure, on the one hand, a clear path leading to compliance with the Cross Comment No. Comments Officer Comments Issue Reference By provisions of the UK Climate Change Act 28; and, on the other hand, the installation of large wind turbine and photo-voltaic electricity generating capacity on a decentralised based which will enable communities of25 or more to become energy (electricity) self-sufficient. And, in respect of transport, to plan for the conversion from fossil fuel-based transport to electricity/hydrogen fuel-based transport.

The Natural Environment. The decline in biodiversity in the natural environment since World War II is well documented, and this is strongly believed to be due to the loss of habitats which sustain this biodiversity and also the introduction of toxic, polluting substances into the environment from a multiplicity of sources. The draft Core Strategy needs therefore not only to address this reality, but also seek to develop policies and strategies which will countermand this Comments noted. The June 2011 consultation trend because, in the final analysis, any definition of a sustainable society is meaningless if the document includes the proposed core policy 33 2892 SO5 deteriorating condition of the natural environment is not arrested and, equally importantly, if its (biodiversity and geodiversity) which seeks to regeneration is not accomplished. In short, we cannot meet the social and economic protect biodiversity. imperatives of sustain ability if the environmental imperative is neglected because, as biological logic makes evident, the delivery and health of the social and economic dimensions of sustainability are entirely dependent on the environment being in a sound condition. We need to see this thinking being clearly evident in the draft Core Strategy. Cross Comment No. Comments Officer Comments Issue Reference By We the undersigned [Members of Parliament, Parish Councils, community groups, etc] have studied Wiltshire Council's draft Core Strategy and have concluded that it does not represent a coherent plan for the future of West and North Wiltshire to 226 and beyond. Last year we were led to believe that the abolition of regional allocations for building new homes in the county would allow us to decide how much development we wanted in Wiltshire and where we wanted it. Today we find that the massive housing estates and retail parks have not shrunk back from the green field sites where the developers would like to build them. Twenty thousand new homes and something like a square kilometre of industrial estates are planned for North and West Wilts by 226 - homes and jobs for another 5, people. We question fundamentally whether this model of expansion can bring the economic growth the council expects, while also meeting the needs of existing communities in an area where transport, education and health services The Core Strategy has a number of policies that are already struggling to meet demand. Clearly, past planning policies have not worked, yet the aims to address a number of the issues raised in Council's Core Strategy is proposing more of the same: • More decline of town centres • More this response. Core Policy (CP) 6 details a plan characterless car-based suburbia • More traffic, congestion, noise and pollution in both towns to regenerate Trowbridge town centre and CPs and villages • More damage to the natural environment and loss of agricultural land • More 42 - 48 detail a comprehensive transport plan for overloaded services Rather than reproduce these outdated policies in the blueprint for the next development and strategies across Wiltshire. The 15 years, we ask the council to think again and give us: 1. An overall reduction in the housing housing and employment being planned for is numbers it has proposed for West and North Wiltshire, seizing the opportunity offered by the based on the most up-to-date evidence available scrapping of regional allocations and fulfilling the promise of a new 'localism' in planning policy; in line with Government advice as detailed in 2. A more honest consultation that provides real data and maps on the traffic implications of topic paper 17. While it is recognised that a proposed growth in our area; 3. Much stronger policies to ensure that people will have real Overall 2893 number of Greenfield sites are being planned for Q22 opportunities to switch from driving to walking, cycling and travelling by bus or train - a key Strategy mitigation and measures to ensure continuing objective of the Wiltshire Community Plan; 4. A better and more informed appraisal of our real protection of the environment are being taken to needs for new jobs and new homes; the relationship between these needs and the skills we ensure that sensitive areas are not damaged by want to develop and attract in coming years; a more direct way to meet the urgent need for development. New maps will be produced for the affordable homes in towns and villages; 5. The channelling of developer funds away from next draft of the Core Strategy. Finally it should building more roads and towards developing and improving town centres, creating 'green be recognised that the Core Strategy does carry infrastructure' and supporting better public transport; 6. The clear prioritisation of Trowbridge legal weight and as such needs to make sure it and other town centres for office development to bring vitality back to central areas; 7. Fewer can stand up to scrutiny, however every effort is new employment areas on the fringe of towns -less 'tin shed land' in the open countryside; made to make it legible for non-planning support for rural employment, farm-based enterprises, local food and working villages; 8. A professionals. sustainability appraisal that genuinely examines the environmental consequences of hot- housing Western Wiltshire, and looks at other options for development in the coming decades of climate change, peak oil, and shortages of food and water; 9. A Core Strategy that is understandable to the ordinary person rather than hiding its objectives in planning jargon and evasive verbiage; 1. The publication of accurate maps to show the proposed locations of housing and employment areas and the roads and other strategic infrastructure and services that the council is planning to provide for them. We consider that the present draft of the Wiltshire Core strategy is not fit for purpose. We ask the Council to think again. Also We the undersigned Need to Protect the area (WELLHEAD DROVE) from the Proposed Easton By- Pass and would like the Wellhead Valley to be made an area of natural beauty. Residents + Visitors of Wellhead Drove - 23 signatures attached. Cross Comment No. Comments Officer Comments Issue Reference By Core Policy 22 – Existing Employment Sites We note that Policy CP 22 states that where land in Market Towns is in established employment use it will be retained, unless one of 6 suggested criteria is met. National planning policy, PPS3, paragraph 44, states that: Considering whether sites that are currently allocated for industrial or commercial use could be more appropriately re-allocated for housing development . National planning policy, PPS4, Policy EC2, requires LPAs to: Ensure that site allocations for economic development, particularly if they are for single and restricted uses, are not carried forward from one version of the development plan to Comment noted. All existing allocations will be the next without evidence of need and reasonable take up during the plan period. If there is no considered to ensure they are developable and reasonable prospect of a site being used for the allocated economic use, the allocation should deliverable. If found not be deliverable / not be retained, and wider economic uses or alternative uses should be considered. It is clear 2898 developable the site will be reconsidered. It is SO1 that the Land at Upside Park has remained undeveloped despite approvals for employment considered that CP22 provides flexibility to enable development. The site owners have advised that a scheme of wholly speculative B Class the re-development of an employment site whilst employment development is not viable, and that an element of housing will be required to fund also ensuring the provision of jobs. the essential infrastructure that is required to deliver the site. Accordingly it is recommended that the following additional excepting criteria is included under Policy CP 22: Vii: in circumstances where historic employment allocations in previous Local Plans, or unimplemented planning permissions have not been taken up, and where viability evidence can demonstrate that the inclusion of an element of non-employment development is essential to deliver the allocation as a mixed-use scheme comprising employment and compatible non- employment uses. Core Policy 28 - Providing affordable homes Policy CP 28 is considered to be unsound for the reasons set out below: The inclusion of a policy on affordable housing within the Core Strategy needs to be based on an evidence of need, provided within a Strategic Housing Market Assessment, and an assessment of the viability of residential development in order to accord with national policies in PPS3: Housing. The Council has not published an SHMA and we understand that while it is noted that a SHMA is being prepared, this has not been completed. The Council has not published a Viability Study. It thus seems premature for the Council to be consulting on a proposed target and thresholds for affordable housing provision. Notwithstanding this issue, we consider that Core Policy 28 should be amended to support housing delivery and to allow the tenure mix of housing development schemes to respond to local needs. The last few years have demonstrated that housing market circumstances and the viability of residential development can change rapidly. Net housing completions in Wiltshire in 29-1 were over 2% down on average levels before 28. An affordable housing policy needs to be flexible to respond to these changes in these circumstances to maintain delivery. Moreover, the collective impact of policies within the plan on the viability of development needs to be considered, including contributions to infrastructure and policies relating to sustainability construction and low carbon energy. This point is clearly made in the draft National Planning 2899 See comment 2874 SO3 Policy Framework which sets out in paragraph 41 that: “Local planning authorities, parishes and neighbourhood forums should assess the likely cumulative impacts on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the development plan at serious risk, and should facilitate development throughout the economic cycle.” A viability study which considers the collective impact of policies within the Plan needs to be undertaken. In the absence of this it is inappropriate to comment further on the percentage of affordable housing sought, or for the Council to set out proposals. It is also important that the mix of housing brought forward through new development schemes responds to and meets local housing need and demand, not just that assessed at a strategic level, county-wide. The Consultation Document makes this point in paragraph 6.3.2 stating that the right homes in the right place at the right time are required to deliver balanced communities and in Core Policy 28 in regard to tenure. Core Policy 28 should provide greater flexibility to tailor housing provision to local needs. Against this context, we consider that 1. Core Policy 28 should be reviewed in light of evidence of housing need/demand from the SHMA, and an assessment of development viability which takes Cross Comment No. Comments Officer Comments Issue Reference By account of other policies in the Plan, including Core Policy 26 and infrastructure requirements. 2. That the wording of Core Policy 28 should be amended to state that affordable housing of up to xx% will be expected on sites of 15 or more dwellings, and a requirement of xx% net onsites of 5 to 14 dwellings, subject to evidence of local need . 3. An additional sentence should be introduced into Core Policy 28 relating to the level of provision, which should support an open book approach to considering the viability of development schemes, taking account of the cumulative impacts of local and national standards and policies, and any abnormal costs related to the development scheme. We consider that this latter point is essential to be consistent with national policy and support housing delivery. Core Policy 29: Meeting Housing Need Core Policy 29 is supported in terms of its ambition to relate housing mix to the needs of local communities. However it is considered that the wording of Policy CP 29 should be subject to further refinement . The policy should have regard not just to local housing need but to demand. The mix of housing in developments should reflect local need and demand, as well as having regard to the needs of Wiltshire. The wording of the policy should be amended as follows: New housing must be well designed to address local housing need and demand incorporating a range of different types, tenures and sizes of housing to create mixed communities. The size and type of housing in developments should have regard to the needs of Wiltshire as set out in the Strategic Housing Market Assessments. Core Policy 3 - Lifetime Homes Standards It is accepted that the underlying objectives of Lifetime Homes Standards are laudable, and that many of the criteria can be readily incorporated into the design of residential development. However, the requirement under Policy CP 3 for all residential development to be compliant with Lifetime Homes standards is considered to be unsound . Compliance with all 16 of the Lifetime Homes criteria is unduly prescriptive, and will create practical implementation consequences that in turn will adversely affect the viability and deliverability of housing development. Paragraph 41 of the consultation draft NPPF requires LPAs to assess the cumulative effects of local policies and national standards. There is no evidence that such a process has been undertaken in respect of Lifetime Homes in the Draft Core Strategy. Examples of the practical consequences of the rigid application of Lifetime Homes Standards are summarised below: Space requirements: for example, in three bedroom dwellings, the increased ground floor WC width and increased circulation space effectively either reduces the lounge width by 75mm or increases the overall floor area by at least 1% which will create a proportionate increase in build cost. We doubt very much if the increased circulation space and WC size, and other requirements such as winder mechanisms on windows, will be seen as necessary, desirable, or good value-for-money by the average home purchaser/occupier. Density: the requirement to place the living area at entrance level effectively rules out 3 or 4 storey houses, where the living space is almost always on the first floor level. This conflicts with increasing density requirements, and with the Code for Sustainable Homes, which awards maximum points for developments incorporating 3 and 4 storey dwellings, and will have a major impact on design in urban areas where such a house style is typical. Car Parking: the increased car parking space requirement will also have a negative effect on density and effective use of land. General needs: evidence from the RSL sector suggests that despite having invested in the requirements of Lifetime Homes very few homes, if any, have undergone the adaptations made theoretically possible by Lifetime Homes i.e. through the floor lifts, hoists, ground floor showers etc. When occupiers get to the point of needing to make the adaptations they generally move to a more appropriately designed homes rather than settle for a make-shift Lifetime Homes conversion. This again questions the value for money of incorporating the requirements wholesale in all new residential development, and suggests that the requirements should be confined to a fixed percentage of properties. Design: forcing designers to follow a specific set of design rules for all properties will inevitably have an impact on the design. For example all properties will be required to have a canopy over the entrance door, even where this is not typical of the local style. It is recommended that the Policy CP 3 is deleted, and that the application of Lifetime Homes standards is negotiated on a case by case basis, where an appropriate percentage of new dwellings could be agreed as being Lifetime Homes compliant. Cross Comment No. Comments Officer Comments Issue Reference By I have been browsing, somewhat belatedly, the Council's recent core strategy consultation document. Whilst I understand that the formal period of consultation is over, might I make a few points to you? 1. The first is about the wording of strategic objective 1 which currently states: to minimise the risk of flooding and effective water management . I think that this will need to be changed as, in effect, it says: to minimise ... effective water management. Perhaps the objective ought to be rephrased? Something like this might be more apt: to minimise the risk of flooding, and promote effective water management. 2. The second point relates to quality of life. I was surprised, at first scrutiny, that this wasn't the focus of a strategic objective, given its significance to people - something like: "to promote the quality of life of families and communities". The idea is, of course, to be found within strategic objective statement 4: to build resilient communities: This strategy includes measures that will help to deliver this objective through putting in place a framework which will provide support for our communities, enabling them to help themselves and improve their quality of life, foster a sense of community belonging, safety, social inclusion and self-sufficiency. My preference would be to have "quality of life" in the objective statement, and, if really necessary, "resilience" in the accompanying text, Noted and agreed - the core strategy is a on the grounds that the former is likely to be much more meaningful to the people of the county comprehensive document and all elements within 2900 SO1 than the latter, which is little more than a piece of jargon which even experts argue over. Were it the strategic objectives need to be achieved to up to me, I should be to drop the word resilience altogether, although I do recognise that it is deliver the outcomes. currently in much vogue in some circles. I am also rather surprised that "families" do not get a mention in this objective, and its key outcomes, given that these (viewed broadly) remain the core social unit that people live within, relate to, and care for. Rather to my astonishment, family / families is used only twice in the whole document, and one of these references is to "the national park family", which hardly counts. I have to say that my astonishment deepens when I remember that this document has been produced by a Conservative administration. 3. My last point relates to the separated nature of these strategic objectives. Of course, to write an objective, one has to separate and codify, making ideas as coherent as possible, and so I am not commenting negatively on the fact that there is a range of such objectives. Rather I am saying that none of these will be really achievable in isolation from the the achievement of the others. As a simple example, climate change, the quality of the built and natural environments, decent homes, vibrant town centres, a thriving local economy, etc, all relate (underpin) the quality of life. I know that you (and the document's authors) know this, but might the paper say so more clearly - perhaps in the text under #3.2?

The parish council notes the strategic objective 10 in the core strategy to minimise the risk of flooding and agrees that new development will need to take due consideration of flooding but questions as to whether any new development should be allowed to be built on potential flood plains and land known to flood. Northern development at Swindon was built on land known to flood and the development included sustainable urban drainage systems which solved the The risk of flooding in the Cricklade and Purton problem within the immediate locality. However it moved the problem further down the River area is well recognised however, flood zones are 2906 Ray to farm land south of the river in the parish of Purton. When it rains, 120 acres of farm land Q22 designated by the Environment Agency and thus is reduce to just a couple of acres for the cows to retreat to. The problem is that water tends to the maps only show these national designations. do its own thing. Purton is built on a hill and so most of the village is unaffected by flooding. However as water runs downhill, it emerges at the bottom of the hill and can cause significant flooding to those houses to the north of the village and beyond towards Cricklade. The areas affected are not shown on your Flood Plans. Amendment required o That no new development should be built on flood plains or areas which are known to flood (also - core policy 49) Cross Comment No. Comments Officer Comments Issue Reference By

Question 22. Having read the consultation document are there any other comments you would like to make on the approach to or content of the consultation document and the emerging Wiltshire Core Strategy. Housing for travellers - there is support for increasing the number of pitches at the Thingley Traveller site on a reasonable scale. However if it is extended, pressure on the infrastructure should be taken into account, particularly on schools. Corsham wants Support for new pitches is noted and will be taken strategic growth, but would seek to ensure a balance of housing and employment along with Gypsy and into. The overarching aim of the document is 2908 improvements to infrastructure such as roads, health, leisure and education. Corsham Town Traveller Q22 sustainable development and the recognition of Council is keen that Corsham develops in a sustainable way with a good balance between pitches this is welcome. social, economic and environmental issues. Our response to the consultation tries to address many of these current imbalances wherever possible. The Town Council is undecided whether it will produce a Neighbourhood Plan at this stage although it is keen to explore the issue further and may feel it is appropriate for part or all of the Parish area and perhaps neighbouring parishes.