Planning Statement Glenmore Farm, Westbury

July 2015

Contents

1. Introduction 1

2. The Proposal 3

3. The Site and Context 5

4. Planning Policy Context 6

5. Planning Assessment 12

6. Planning Obligations – Draft Heads of Terms 24

7. Summary and Conclusions 26

Contact Andrew Ross [email protected] Client Taylor Wimpey

LPA Reference Wiltshire Council

July 2015 1. Introduction

1.1 This Planning Statement has been prepared by Turley to accompany an outline application for planning permission submitted by Taylor Wimpey for up to 145 dwellings at Glenmore Farm, Westbury.

1.2 In addition to this Planning Statement the following documents also accompany the application and provide the information necessary to describe, assess and determine the proposals.

• Site Location (Red Line) Plan – Ref. TAYA2036_1001B;

• Buildings to be Demolished Plan – Ref. TAYA2036_4401;

• Access Plan – Ref.27325-002-006A;

• Illustrative Masterplan – Ref. TAYA2036_3207B;

• Land Areas Plan – Ref. TAYA2036_3602;

• Design and Access Statement;

• Planning Statement - including Draft Heads of Terms;

• Topographical Survey;

• Statement of Community Involvement;

• Transport Assessment;

• Landscape and Visual Impact Assessment;

• Ecological Impact Assessment Report;

• Ecological Mitigation and Enhancement Strategy;

• Flood Risk Assessment;

• Utility Infrastructure Site Appraisal;

• Phase 1 Ground Condition Assessment;

• Tree Survey;

• Noise Assessment Report;

• Historic Environment – Desk Based Assessment;

• Historic Environment – Gradiometer Survey Report;

• Agricultural Land Classification Report;

1 • Additional CIL questions;

1.3 This Planning Statement is structured as follows:

• Description of the proposal (Section 2);

• Description of the Site and Context (Section 3);

• A summary of the Planning Policy Context (Section 4);

• Planning Assessment (Section 5);

• A summary of Section 106 Agreement Heads of Terms (Section 6); and

• Summary and Conclusions (Section 7).

2 2. The Proposal

2.1 The proposal seeks outline planning permission for up to 145 dwellings and associated development. All matters are reserved for subsequent approval with the exception of the main access to the site from The Ham (B3097).

2.2 The full description of the development is set out in full below:

“Outline planning application for residential development (up to 145 dwellings), following demolition of existing dwelling and outbuildings, with public open space, engineering works and associated infrastructure, access to be approved only, all other matters reserved.”

2.3 In summary the proposal seeks to provide:

(a) A mixed residential development comprising a variety of house types and tenures, with up to 145 dwellings, including 30% affordable housing (i.e. up to 43 dwellings);

(b) Safe new pedestrian and cycle routes, linking The Ham with the West Wilts Trading Estate and committed Hawkeridge Business Park to the North;

(c) An integrated network of Green Infrastructure including enhanced habitat and attractive areas of public open space, including an equipped area of children’s play;

Environmental Impact Assessment

2.4 A request for an EIA Screening Opinion was issued to Wiltshire Council on 10th July 2014 in accordance with Regulation 5 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 2011. An EIA Screening Opinion was received from Wiltshire Council on 30th July 2014 confirming that the proposed development is unlikely to have any significant environmental effects, and therefore does not constitute ‘EIA development’ as defined by the Regulations.

2.5 Accordingly no Environmental Statement (ES) has been prepared to accompany these proposals; however, a number of technical reports are submitted (as listed in Section 1) which provide all relevant information to enable the Council to assess and determine the submitted planning application.

Pre-application Engagement

Pre-application Submission to Wiltshire Council 2.6 Taylor Wimpey has undertaken engagement with Wiltshire Council via the submission of a formal pre-application submission. A meeting was held with Council Officers on the 31st July 2014. A detailed comprehensive written response was received dated 14th August 2014.

3 Public Consultation 2.7 This application is accompanied by a Statement of Community Involvement (SCI) which outlines the public consultation which has been undertaken to inform the application proposal. This has comprised stakeholder meetings and a public exhibition event on 14th July 2014. As set out with the SCI (and within the Design and Access Statement) feedback has informed the proposed development, including the illustrative design shown the submitted masterplan.

4 3. The Site and Context

Site and Surroundings

3.1 The location of the site, which is to the North West of Westbury, is shown on the submitted site location plan. The site area is approximately 9.8ha and currently comprises buildings associated with Glenmore Farm (a dwelling, areas of storage and land in equestrian use). The site is divided internally by hedgerows and fences, with hedgerows at the boundaries (although these are incomplete in places.

3.2 The north western boundary of the site adjoins West Wilts Trading Estate. The site is bound to the east by Hawkeridge Road (B3097) and to the south by The Ham (B3097), with existing vehicular access taken from both of these roads. The western boundary adjoins existing residential properties and associated gardens, and agricultural land.

3.3 The site slopes down from south to north with a steeper slope downwards south to north from the hedgerow line bisecting the site south west to north east. All of the site is located in Flood Zone 1, as defined on the Environment Agency flood map, that being land at the lowest probability of flooding.

3.4 Further information regarding the site and the local context and character is provided within the submitted Design & Access Statement, as well as other application documents.

Relevant Planning History & Background

3.5 In terms of planning history searches undertaken with Wiltshire Council have not revealed any significant previous planning applications relating to this site.

3.6 The site was not allocated for residential development in the West Wiltshire District local Plan adopted June 2004. However, the site was considered suitable in the Wiltshire Strategic Housing Land Availability Assessment (SHLAA) 2012. The SHLAA considered the application site under ref. 1014 and part of site ref. 742 and concluded that 82%-75% of the land is likely to be developable for residential purpose taking account of public open space, roads, strategic landscaping etc. The SHLAA assessment suggested that the site was deliverable in the 6-10 year timeframe i.e. 2018-2023. The supporting information submitted with this application confirms that the site is deliverable sooner than this.

5 4. Planning Policy Context

Overview

4.1 The application site is not ‘allocated’ for development within any local planning policy documents and is outside of the settlement boundary which is defined for Westbury by the Wiltshire Core Strategy (Bradford on Avon, Melksham, Trowbridge and Westbury Community Areas Map)). The settlement boundary is proposed to be amended through the emerging Housing Site Allocations DPD and the site remains outside of the settlement boundary on the Draft Proposals for Revised Settlement Boundaries map for Westbury. Wiltshire Council is unable to robustly demonstrate a deliverable five year housing land supply. Whilst as a matter of law the Development Plan is the starting point for the consideration of this planning application, the housing requirement within the adopted plan is a minimum, and the emerging DPD that is required to identify sites and amend settlement boundaries is at an early stage of production. The ‘presumption in favour of sustainable development’ (as set out in the NPPF and requiring a positive approach to all decision making to ‘significantly boost the supply of housing’) remains a significant material consideration.

4.2 The relevant policy position and considerations in respect of this application are considered further under relevant headings below.

The Development Plan

4.3 Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that:

“If regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise.”

4.4 With respect to the proposed development site the ‘Development Plan’ currently (at the time of writing) comprises the saved policies of the West Wiltshire District Plan 1st Alteration (2004-2011), the West Wiltshire Leisure and Recreation DPD (2009) and the adopted Wiltshire Core Strategy (2006-2026).

4.5 Other material considerations include:

• The National Planning Policy Framework (NPPF) and National Planning Practice Guidance (NPPG);

• The emerging Wiltshire Hosing Site Allocations DPD, and associated evidence base documents.

4.6 Whilst the Development Plan is the starting point for making determinations under the Planning Acts, other up to date material considerations may also be relevant. The planning policy within the NPPF remains an important consideration in the determination of this planning application.

6 4.7 The adopted Wiltshire Core Strategy does not update all relevant Development Plan policies relating to the provision of housing in Wiltshire and the Council is not able to robustly demonstrate a deliverable five year housing land supply. Even if a marginal five year supply were shown to exist this is not a bar to granting planning permission for further sustainable development, and it is important that a continuous (rolling) supply of housing land is created and maintained.

4.8 The adopted Wiltshire Core Strategy housing policies do not meet the full objectively assessed housing need for Wiltshire and sufficient land to deliver the adopted housing requirement has not yet been identified as the Site Allocations DPD is still at the early stages of production. On this basis the Paragraph 14 ‘presumption in favour of sustainable development’ remains relevant and it is necessary to specifically weigh the benefits of development, against any significant and demonstrable harm.

The National Planning Policy Framework (NPPF)

4.9 The NPPF was published on the 27th March 2012 and sets out the Government‘s planning policies for England and how these are expected to be applied.

4.10 At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision- taking. Sustainable development includes three elements – economic, social and environmental.

4.11 NPPF Paragraph 7 advises that there are three dimensions to sustainable development:

1. An economic role – the planning system should contribute to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and co-ordinating development requirements, including the provision of infrastructure;

2. A social role – planning should support strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and

3. An environmental role – the system should contribute to protecting and enhancing our natural, built and historic environment, including using natural resources prudently, minimising waste and pollution and mitigating and adapting to climate change, including moving to a low carbon economy.

4.12 It is also explicit that in making decisions on planning applications this means:

 “approving development proposals that accord with the development plan without delay; and

7  where the development plan is absent, silent or relevant policies are out-of- date, granting permission unless:

 any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole; or

 specific policies in the Framework indicate development should be restricted”.

4.13 Paragraph 47 sets out the Government’s aim to significantly boost the supply of housing. It states Councils should:

• Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;

• Identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with an additional buffer of 5%. Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20%;

• Identify a supply of specific, developable sites or broad locations for growth, for 6-10 years and, where possible, for years 11-15;

• Illustrate the expected rate of both market and affordable housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy; and

• Set out their own approach to housing density to reflect local circumstances.

4.14 Paragraph 49 of the NPPF states that:

“Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites.”

4.15 In this case the Council cannot robustly demonstrate a deliverable supply of housing land and therefore the Paragraph 14. “presumption in favour of sustainable development” is relevant to the determination of this planning application.

National Planning Practice Guidance March 2014 4.16 The National Planning Practice Guidance (NPPG) supports the NPPF and provides guidance on housing and economic development needs and availability assessments.

4.17 The NPPG contains sections on ‘housing and economic development needs assessments’ and ‘on housing and economic land availability assessment’. The ‘need’ part of the guidance contains a detailed methodology as to how the objectively assessed need should be calculated. Furthermore, the PPG supports the Sedgefield approach when dealing with undersupply of housing by stating ‘Local planning

8 authorities should aim to deal with any undersupply within the first 5 years of the plan period where possible’ (Paragraph: 035).

Development Plan

West Wiltshire District Plan 1st Alteration 2004-2011

4.18 The former West Wiltshire District Council adopted the West Wiltshire District Plan 1st Alteration in June 2004. Wiltshire Council has inherited the local plans produced by the former district councils in Wiltshire. On 26th September, 2009, the Secretary of State issued a direction setting out the policies within the West Wiltshire District Plan 1st Alteration (2004) that can be 'saved' beyond 26th September 2009. Appendix D of the adopted Core Strategy sets out which of these policies will continue to be saved, those which have been deleted and those which have been replaced by policies within the Core Strategy. Whilst these saved policies remain relevant as part of the current Development Plan the plan’s end date has passed in 2011 (some three years ago) and the policies were prepared and adopted some ten years ago, on this basis none of these policies are considered to carry significant weight in the determination of this application and it is not considered that any of the remaining saved policies are relevant to this proposal. .

West Wiltshire Leisure and Recreation DPD (2009) 4.19 This DPD continues to be saved following the adoption of the Core Strategy and sets out policies for the provision of open space and recreation facilities within new development.

Wiltshire Core Strategy 4.20 The final report of Inspector Andrew Seaman (in respect of the Examination of the Wiltshire Core Strategy) was published on the 1st December 2014. Overall it is concluded that (with proposed modifications) the document is sound and forms an appropriate basis for spatial planning in Wiltshire. The Council expects to consider the final adoption of the Core Strategy at a special Council meeting on the 20th January 2014.

4.21 The Wiltshire Core Strategy was formally adopted on 20th January 2015 and now forms the main policy document against which applications will be assessed. The Core Strategy Inspector found that the objectively assessed housing need for Wiltshire is in the order of 44,000 dwellings over the plan period. However he recommended the adoption of the plan with an overall minimum housing requirement of 42,000 dwellings alongside a commitment to partially review the Core Strategy and to produce an updated SHMA by early 2016. Policies within this plan considered relevant to this application are summarised below.

4.22 The Core Strategy identifies Westbury (Core Policy 1) as a Market Town and a location for strategic employment growth; as such it is a sustainable location to accommodate further development.

4.23 Core Policy 2 requires at least 42,000 new homes across Wiltshire with a minimum requirement of 24,740 for the North and West Wiltshire HMA, this includes Westbury.

9 4.24 Core Policy 32 sets out the Spatial Strategy for Westbury Community Area to include approximately 1,615 new homes and 18.5ha of new employment land over the plan period. Growth in the Westbury Community Area over the plan period may consist of a range of sites in accordance with Core Policies 1 and 2.

4.25 Core Policy 43, states that affordable housing provision of either 40% or 30% will be provided on sites of 5 or more dwellings, subject to viability and other considerations.

4.26 Core Policy 51 states that development should protect, conserve and enhance landscape character and be sympathetic to the distinctive character areas identified in the relevant Landscape Character Assessment.

Wiltshire Core Strategy Partial Review 4.27 As required by the Core Strategy Inspector, the Council are undertaking an early review of the Core Strategy. Initial work has been undertaken on this with a Scoping Consultation Document being available for consultation between 13 April and 26 May 2015.

Emerging Wiltshire Housing Site Allocations DPD 4.28 The Core Strategy Inspector identified that existing settlement boundaries within Wiltshire are not up-to-date and need to be reviewed as soon as possible. On this basis and given the need to identify additional sites for housing to ensure a deliverable five year housing land supply a further DPD is being prepared. The current Wiltshire LDS suggests adoption of this DPD in July 2015, however this will not be achieved as (to date) only a scoping consultation has been undertaken, and no draft DPD has yet been prepared or published.

Community Infrastructure Levy (CIL)

4.29 As of 18 May 2015 the Wiltshire CIL will be charged on all eligible development granted planning permission. All development with at least 100sqm of new build or that results in one new dwelling will be liable and there are two differently priced charging zones. Westbury Community Area is within Charging Zone 2 where residential development will be charged £55 per sqm.

Planning Policy Summary

• The national planning policy contained within the NPPF, including the Paragraph 14 presumption in favour of sustainable development, is a material consideration for the determination of this planning application;

• Policies within the West Wiltshire District Plan 1st Alteration are out of date, and none of the remaining saved policies are relevant to the determination of this planning application;

• The adopted Core Strategy includes a minimum housing requirement figure, although this does not reflect the full objectively assessed need for housing in the County and is to be subject to review based on a new SHMA by early 2016;

10 • There are not development boundaries within the Development Plan which are ‘up-to-date’ and this needs to be addressed by the preparation of a further Development Plan Document (the emerging Wiltshire Housing Site Allocations DPD);

• The Core Strategy was adopted with a requirement figure not reflecting the full objectively assessed need, this was deemed acceptable by the Core Strategy Inspector on the basis that an early review of the Plan was undertaken and a revised SHMA produced in 2016. However a recent appeal decision (ref. APP/Y3940/W/14/2222641) has concluded that the Council cannot currently demonstrate a 5 year supply of deliverable housing sites in the North and West HMA when the buffer required by the Framework is applied. Although this shortfall is marginal the existence of a five year land supply is not a bar to granting further permission for sustainable development, and it is essential (to meet the requirements of national policy and the growth aspirations within the Core Strategy) for a continuous/rolling supply of deliverable housing land to be maintained;

11 5. Planning Assessment

5.1 This section provides an assessment of the proposed development with reference to the planning policy context provided in previous sections, amongst other things. This focuses on housing need and delivery in Wiltshire (particularly within the North and West HMA), the economic benefits of development and specific issues associated with the suitability and deliverability of the application proposals. For full details of the application proposals and specific technical matters, reference should also be made to all other submission documents.

Need for Development

Housing and Housing Land Supply 5.2 As set out in previous sections, the NPPF confirms the Government’s requirement (policy) to significantly boost the supply of housing, including requiring Local Authorities to meet the full, objectively assessed needs for market and affordable housing in their housing market areas.

5.3 The NPPF also requires Local Authorities to identify a supply of specific deliverable sites sufficient to provide five years’ worth of housing (against their housing requirements) with an additional buffer of 5%. Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20%. This is not additional housing but land supply brought forward from later periods to help ensure that requirements are met.

5.4 Where a five year supply cannot be demonstrated, Paragraph 14 of the NPPF is clear that planning permission for residential development should be granted unless any adverse impact would “significantly and demonstrably outweigh the benefits” of doing so.

5.5 In the context of this application it is therefore important to consider whether the Council can demonstrate a five year supply of deliverable housing sites.

Housing Requirement 5.6 The Core Strategy establishes a need for “at least” 42,000 dwellings over the plan period (2006-2026). The Core Strategy Inspector’s Report states:

“Overall, the balance of evidence suggests that the objectively assessed housing need, to be disaggregated across the three Wiltshire HMAs, is currently in the region of 44,000 dwellings over the plan period.”

5.7 Going on to consider a range of other factors, including the preparation of other DPDs and the preparation of a new SHMA (by early 2016) to inform a review of the plan the Inspector concludes that:

“I consider that at this time the minimum housing figure within the CS should reasonably equate to at least 42,000 homes over the plan period with the flexibility to deliver more.”

12 5.8 The need for an early review of the housing requirement is set out in the Core Strategy at paragraph 4.29. This was further considered in a recent appeal decision for Land at Westbury Road, Great Cherwell where the Inspector reiterated that the Core Strategy Inspector’s finding of soundness in relation to the Core Strategy as a whole was predicated on a commitment to a planned early review.

5.9 The Wiltshire Core Strategy sets a housing requirement of ‘at least’ 42,000 dwellings, with at least 24,740 in the North and West HMA, i.e. 1,237dpa. Therefore based on the Core Strategy requirement the basic housing requirement for the period 2014-2019 is at least 6,185. With a 5% buffer this increases to at least 6,494 (1,299dpa) and with a 20% buffer to at least 7,422 (1,484dpa). As highlighted above this is a minimum figure, does not reflect the full objectively assessed housing need for the area and has been found acceptable on the basis of the preparation of further DPD’s and a future review (updated SHMA).

Housing Supply 5.10 The July 2014 Wiltshire Housing Land Supply Statement states the deliverable housing supply for the period 2014-2019 to be 7,178 in the North and West HMA. Although the Core Strategy Inspector has accepted this figure (with qualifications) a figure of only 6,823 for the same period was agreed by the Inspector and SoS in respect of the Park Road, Malmesbury appeal.

5.11 At a recent appeal relating to Land at Bath Road, Corsham the Council presented evidence stating that they have a claimed deliverable supply for the North and West HMA of just 6,530 dwellings.

Five Year Housing Land Supply 5.12 It is clear from the information set out above that taking the ‘best case’ scenario (comprising the Council’s supply figure, a 5% buffer and the minimum requirement) a marginal five year land supply would exist. However should the actual supply be less than claimed (which is very likely given delay on a number of strategic sites), applying a 20% buffer (which better reflects the ambition of the NPPF and past performance within Wiltshire) and with regard to the actual requirement figure being a minimum – the type of deliverable land supply which is anticipated by the Government through the NPPF, to ‘significantly boost’ the supply of housing is not available.

5.13 The Land at Bath Road, Corsham appeal Inspector found that the Council cannot currently demonstrate a five year supply of housing in the North and West HMA. The shortfall is marginal, however it is clear that the Council cannot robustly demonstrate a deliverable five year supply of housing land; significant weight should therefore be attached to the positive benefits of proposals which would help to secure and maintain a suitable supply of deliverable land and the general benefits associated with increased housing delivery. Continuing delay in respect of the delivery of key large development sites in the County means that this position is unlikely to significantly improve without additional deliverable sites being identified to help bring forward development.

5.14 In any event the existence of a deliverable five year supply does not represent a bar to granting permission for further sustainable development as considered within the context of a planning appeal at Launceston, Cornwall (11th April 2014, Ref: APP/D0840/A/13/2209757).

13 5.15 In particular, at Paragraph 51 of this decision the Inspector confirmed that:

“irrespective of whether the 5 year housing land figure is met or not, NPPF does not suggest that this be regarded as a ceiling or upper limit on permissions. On the basis that there would be no harm from a scheme or that the benefits would demonstrably outweigh the harm, then the view that satisfying a 5 year housing land supply figure should represent some kind of limit or bar to further permissions is considerably diminished, if not rendered irrelevant. An excess of permissions in a situation where supply may already meet the estimated level of need does not represent harm, having regard to the objectives of the NPPF”.

5.16 Particularly in Wiltshire where the housing requirement is a minimum and does not reflect the full objectively assessed need for housing in the area, the existence of a five year housing land supply should not be seen as a bar to the grant of further planning permissions for sustainable development. By contrast, it is very clear that if permission is to be refused there needs to be a clear demonstration of ‘harm’ with reference to the particular credentials of the site in question.

Housing at Westbury 5.17 The latest summary assessment of supply contained in the adopted Core Strategy suggests an indicative remainder of at least 168 dwellings at Westbury, based on completions since 2006 and current ‘developable commitments’. The application proposals seek permission for a proportion of this indicative remaining requirement and will help to ensure the necessary housing is delivered promptly. In addition, the following material points concerning the suitability of Westbury for development and the benefits of the proposed development need to be considered:

• The overall housing requirement within the emerging Core Strategy (on which these figures are based) is a minimum, this remainder is therefore a minimum figure;

• This figure includes committed allocations from the previous local plan which have not yet been realised and for the Council’s strategic allocation, which is acknowledged to have viability issues as discussed at the Core Strategy examination hearings;

• Westbury is a highly sustainable location and a suitable location for additional development, to complement the substantial existing and proposed employment base, and given the excellent public transport connections which are available;

• National planning policy is to boost significantly the supply of housing, based on a presumption in favour of sustainable development;

5.18 Westbury has a historical trend in the successful delivery of housing, however figures provided during the examination of the Core Strategy suggest a reduction in average build rates. The sustainability appraisal which accompanied the Council’s plan ceased to identify air quality or traffic as issues constraining the overall quantum of development achievable in the area.

14 5.19 Despite having some of the best sustainability credentials of all Wiltshire towns, this is not reflected in the Core Strategy policies for the area, which suggest a slowdown in rates of housing delivery, which would not help to achieve the economic aspirations for the area (including regeneration of Westbury town centre) and where there are few environmental constraints. Overall Westbury is a highly sustainable location and further housing would represent sustainable development for the town, the ‘indicative remaining requirement’ of 168 dwellings at Westbury is a minimum figure and further housing would help to meet wider needs (including the need for affordable housing) within the Community Area and this part of Wiltshire (the North and West HMA).

Affordable Housing 5.20 As in many areas there is a significant need for affordable housing within Wiltshire, and it is acknowledged that the Core Strategy will deliver a shortfall when measured against levels of need. The adopted Core Strategy seeks to deliver some 13,000 new affordable homes in Wiltshire over the plan period which amounts to a rate of 650 a year. Affordable housing completions data for Wiltshire since 2009 is shown in the table below. Whilst a reasonable level of performance has been achieved, completions have been below the annualised target (which is itself below levels of need) in four out of five years, with a cumulative shortfall of 56 and no data available for the first three years of the plan period. Accordingly the delivery of affordable housing, together with the general provision of housing which helps to boost supply and increase availability, choice and affordability, is a significant benefit of the proposed development.

Year Wiltshire Affordable Housing

2013/14 645

2012/13 711

2011/12 626

2010/11 648

2009/10 564

Conclusion on Housing Requirement and Five Year housing Supply 5.21 Overall the following key points are material to the consideration of the planning application submitted by Taylor Wimpey at Glenmore Farm, Westbury:

• As evidenced by the recent Corsham appeal decision, Wiltshire Council is unable to robustly demonstrate a deliverable five year housing land supply for the North and West HMA. It is necessary to ensure a continuous/rolling supply of deliverable housing land and current calculations are based on a minimum figure which does not reflect the full objectively assessed need for the area and only incorporates a 5% (rather than 20%) buffer;

15 • The provision of housing (including affordable housing) is a key benefit of the application which attracts significant weight, and takes on increased importance given the lack of a decisively demonstrated deliverable five year housing land supply;

• Planning policy is to ‘boost significantly’ national housing supply, and even were a deliverable five year land supply proven and the ‘indicative remaining (minimum) requirement’ for Westbury met, the provision of housing in a highly sustainable location is a significant benefit of the proposals – provision of housing over and above the minimum level does not amount to harm;

Site Suitability and Deliverability

Development at Westbury 5.22 The principal of development at Westbury, and the appropriateness and need for development at Westbury, is established in extant and emerging planning policy and has been discussed above.

5.23 Westbury is a highly sustainable location for further development, benefiting from significant areas of existing and proposed new employment, a range of facilities and services, and significant public transport links – particularly the ability to travel by rail to the North, South, East and West. Furthermore there are long held aspirations to improve the vitality of Westbury Town Centre, and further development can help towards this goal.

Suitability of the Application Site 5.24 The site has been confirmed as developable by the detailed technical assessments that have informed the proposed development and are submitted to accompany this application for Outline Planning Permission.

5.25 The site is well located in relation to public transport provision, schools and shops, in addition to employment, leisure and medical facilities. It is therefore considered to be a sustainable and appropriate location for development.

5.26 Further information is set out in other documents submitted in support of this application including the Design and Access Statement and the Transport Assessment.

5.27 In comparison to some other possible development sites around the town the site is very well located for access to the significant areas of existing employment at the existing Trading Estate and proposed business park, as well as being conveniently located for Westbury rail station. The site is also able to deliver site specific benefits, including the provision of a direct and convenient segregated new pedestrian and cycle link to the Eastern end of the trading estate and proposed new business park.

Economic Benefits of Development 5.28 National Planning Policy contained within the NPPF requires the delivery of sustainable development, part of which is economic and relates to the concept that sustainable development means development and growth (as specifically identified in the forward to the document).

16 5.29 The economic benefits of the proposed development are significant and should be afforded due (substantial) weight in the determination of this planning application. Paragraph 19 of the NPPF specifically identifies that the government is committed to ensuring that the planning system does everything it can to support sustainable economic growth, and that therefore ‘significant weight should be placed on the need to support economic growth through the planning system’.

5.30 With respect to sustainable development the economic element, as defined within the NPPF, refers to:

“Contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth; and by identifying and coordinating development requirements, including the provision of infrastructure”

5.31 The Glenmore Farm site at Westbury is a sustainable location and is available for development now. New housing in this location would help to contribute to growth in the local and wider economy of this part of Wiltshire. Whilst there is no direct provision of new employment land the provision of housing and spin off benefits associated with this helps to support wider economic objectives. Some further economic benefits of the proposed development are further summarised below:

• Potential for up to 145 new dwellings to support and create construction jobs and indirect and induced construction-related jobs over the 3 year build period;

• Net additional retail (and other) expenditure from new residents for the operational lifetime of the development;

• 30% affordable housing, which will ensure the availability of accommodation for ‘key workers’ and other elements of the local labour force;

• Some £1,363,671 in New Homes Bonus income, plus additional Council Tax payments in perpetuity;

• CIL payments of some £797,500.00;

• A package of relevant S106 infrastructure contributions to mitigate impacts arising from the proposed development, but may deliver additional benefits for existing communities.

Deliverability 5.32 Taylor Wimpey is a national house-builder with the expertise and resources to ensure the timely and efficient delivery of new housing at the site; these proposals have been subject to pre-application discussion and consultation and it is hoped that the Council can therefore expediently determine this application.

17 5.33 The proposed development is capable of contributing to the delivery of housing in the next five year period, as well as improved community infrastructure through the CIL contributions and proposed S106 package.

5.34 Other key issues that have been taken into consideration include:

• Design and Layout;

• Transport and Access;

• Noise;

• Landscape and Visual Impact;

• Ecology;

• Archaeology/Heritage;

• Sustainable Construction

5.35 Each of these issues is addressed in turn, below.

Design and Layout

5.36 The proposals are for the provision of up to 145 residential dwellings and the development would achieve an average net density of approximately 30 dwellings per hectare (dph) which relates well to the existing density of development adjoining the western boundary of the site, and also ensures effective/efficient use of the land.

5.37 Dwellings proposed across the site will comprise a range of house types, sizes and tenures and are envisaged to accommodate a variety of household types.

5.38 An element of affordable housing will be provided within the development in appropriately sized clusters, although the precise tenure split is to be agreed with the Council it is expected that this will include both rented and shared ownership homes.

5.39 The illustrative layout has been designed to enable the retention of existing site features and provide connectivity with the existing town and surrounding uses – in particular the provision of new pedestrian and cycle connections between The Ham and the existing trading estate and proposed business park to the North is a significant benefit.

5.40 Full details of proposed format of the development are included within the Design and Access Statement, this has evolved to take account of both technical issues and feedback received during public consultation and engagement.

Transport and Access 5.41 Overall Westbury, and the proposed development site, is a sustainable location and transport and access considerations have been integrated as part of the proposals to ensure accordance with relevant national and local policy and guidance. A detailed Transport Assessment accompanies the planning application.

18 5.42 The development will provide a total of 5 connections (the main vehicular access, three further pedestrian and cycle connections and a separate emergency access point) to the existing road network creating a fully connected and permeable street layout, this includes highway access via a new priority junction on the south eastern boundary of the site with The Ham.

5.43 Pedestrian access to the site will be gained via the extension of the existing footways on The Ham across the south western frontage of the site, and to the Link Road junction to the north of the site providing a connection to the West Wilts Trading Estate.

5.44 The existing public transport facilities are good, particularly in regard to rail links connecting Westbury with most major destinations in southern England, offering the possibility of longer distance journeys without the need of a private car. Westbury rail station would be easily accessible for the proposed development

5.45 The existing road network is of a good condition and well aligned in the vicinity of the site. Based on the existing conditions on the surrounding highway network and a review of the accident history within the area, it is not considered that the proposed development will result in any highway safety concerns and measures to improve connections and local highway safety have been considered in response to specific comments received during the preparation of the planning application.

5.46 The development allows an improved sustainable connection to be made to the consented Hawkeridge Business Park development (as well as the Eastern end of the West Wilts Trading Estate) and this is a significant benefit of the application proposals.

5.47 The multi modal trip generation of up to 154 private houses was determined with reference to the TRICS 2014(a) database and the 2011 Census data for the Westbury North Ward. The proposed development is forecast to generate 153 and 155 external person trips in the AM and PM peak hours respectively, based on relevant multi modal analysis the proposed development is forecast to generate 75 and 76 vehicle trips in the AM and PM peaks respectively.

5.48 Overall it has been shown that safe access can be achieved to the proposed development, that the development would have a negligible impact on the operation of the local highway network and that there are local public transport connections which help to ensure the sustainability of the site for housing development. A key benefit of the application proposals is the creation of new pedestrian and cycle routes linking The Ham (and rest of Westbury) with the Eastern end of the West Wilts Trading Estate and the proposed Hawkeridge Business Park, where currently no off-street routes/foot/cycle ways exist.

Noise 5.49 To assess the application site and inform the proposed development noise surveying and assessment has been undertaken, to ensure that appropriate noise conditions for the proposed dwellings can be achieved. Full details are set out in the Noise Assessment report which accompanies this application prepared by Hepworth Acoustics. Surveys have been used to determine daytime and night-time noise levels attributable to road traffic, rail traffic, an electrical substation, industrial noise sources and noise associated with the Club Ice night club.

19 5.50 It has been determined that road traffic and rail noise do not present any material constraint to the proposed development, however noise mitigation measures will be required for proposed residential development plots close to the site boundaries with The Ham and Hawkeridge Road to achieve an appropriate noise environment for residential purposes in line with the guidance set out in BS 8233. Such measures will be readily achievable, to be included at subsequent detailed design (Reserved Matters stages), and controlled by way of a suitable planning conditions.

5.51 It has been determined that the nearby electrical substation presents no constraint to the proposed development.

5.52 Although an infrequent source of noise it has been determined that Club Ice night club generates noise levels that require mitigation at proposed residential development plots, this mitigation will be achievable and enforced for planning purposes by way of a suitable planning condition. As set out in the Hepworth Acoustics report appropriate sound insulating building fabric is recommended in response to the ‘worst-case’ night club noise as detailed in the report.

5.53 The information provided with this Outline planning application shows how an acceptable development can be achieved on the site, having regard to the prevailing noise environment and all other material planning considerations, ensuring compliance with relevant national and local policy and guidance, where there are no fundamental reasons (related to noise) not to allow outline planning consent for residential development.

Landscape and Visual Impact 5.54 A detailed landscape and visual impact assessment has been undertaken to inform the proposed development, this is provided as a separate document as part of the Planning Application.

5.55 In terms of the effect of the proposals upon the visual environment, it is considered that the proposals will have a moderate/minor effect overall and that effects will be limited to the immediate setting of the site. The proposals will be seen within the context of the existing urban area, between the West Wilts Trading Estate and residential development and will not extend the existing built edge. The visual influence of the proposals is considered to be highly localised, with the introduction of the proposals being compatible with the urban fringe setting of the site when viewed from the wider context.

5.56 Whilst it has been noted that there will be some harm to the visual environment of the immediate context to the south/south east along the B3097, the existing built up edge of Westbury however already forms a key component in these views and the site currently forms a transitional urban fringe zone that has the capacity to accommodate this degree of change. The potential suitability of the site’s capacity to accommodate housing development has also been acknowledged within the SHLAA, which raised no significant landscape constraint.

5.57 In landscape terms, the proposed development will generally have a moderate/minor effect on the character of the localised and wider landscape setting including the higher ground to the south east, or the wider character of the town due to the localised nature of the change. The application site will form part of a natural extension to the existing

20 urban area, will not extend the built presence beyond the existing urban edge and ensures a buffer is maintained between the adjacent industrial areas. The current characteristics of the immediate landscape include extensive urbanising and human influences ensuring that the proposed development would not be out of context to that which currently exists. The proposed development will also will reflect the pattern of existing residential development to the south west and includes extensive green infrastructure.

5.58 It is considered that the application site and receiving environment have the capacity to accommodate the proposals. The proposals will not result in significant harm to the landscape character or visual environment and, as such, it is considered that the proposed development can be successfully integrated in this location, and meets the landscape requirements of both national and local planning policy.

5.59 A landscape strategy plan is provided as part of the submitted Landscape and Visual Impact Assessment which shows how landscape proposals can be successfully incorporated as part of the development of the site.

Ecology 5.60 A full detailed Ecological Impact Assessment has been undertaken in respect of the application proposals and this is reported in the separate document which accompanies the planning application, together with a proposed mitigation and enhancement strategy.

5.61 The ecological inputs associated with this project have included relevant surveys for all necessary flora and fauna, the results of which have informed the application proposals (including the illustrative masterplan), as well as the range of avoidance, mitigation and enhancement measures detailed in the relevant documents. These measures will be considered alongside future detailed design (Reserved Matters) and can be controlled through use of appropriate planning conditions on an Outline Planning Permission.

5.62 The consideration of ecological resources and the need for mitigation and enhancement measures has been integral to the masterplanning process. In particular this has included the retention and enhancement of significant hedgerows which surround and cross the site, so as to retain and enhance habitats known to be used by protected species. This relates specifically to bat activity in the area, where due to the low level of activity of notable species, and proposals for retention and enhancement of key features known to be used by these bats, it is not considered likely that the proposed development will result in significant effects on the Bath and Bradford-on-Avon SAC populations.

5.63 An Ecological Mitigation and Enhancement Strategy has been produced alongside development and landscape proposals for the Site. Subject to the implementation of the measures proposed within the Strategy it is not considered that the proposed development will result in significant negative ecological impacts. Details of ecological enhancement measures will be agreed with the LPA Ecologist at the reserved matters stage, and a commitment to achieving net gains for biodiversity has been made.

5.64 The proposed development Site is within 10km of the Salisbury Plain SPA/SAC and the River Avon SAC. Relevant S106 contributions have been proposed to mitigate impacts to international sites.

21 Archaeology/Heritage 5.65 The application site is not located adjacent to the Westbury Conservation Area or any specific listed buildings. There will be no adverse impacts on any above ground heritage assets or their setting.

5.66 An archaeological desk based assessment and gradiometer survey has been undertaken and accompanies the submitted application. Further specific investigations, reflecting identified archaeological interest in the area, have been recommended by the Council’s Archaeological Officer and these are ongoing. The full potential and significance of any such archaeological remains will be identified prior to the commencement of any development on site. A precautionary approach has been taken in respect of the illustrative masterplan submitted with the application - the area of the site which has shown most potential for archaeology has been shown undeveloped as an area of new public open space.

Agricultural Land 5.67 To assess the application site and inform the proposed development a desk based Agricultural Land Quality Assessment has been undertaken and accompanies this submission. This desktop study has assessed the characteristics of the site in relation to an assessment of its Agricultural Land Classification. The site has been found to have some of the lowest quality land available around the urban edge of Westbury. Suitable, NPPF compliant mitigation measures (comprising the potential retention and reuse of soil resources) are outlined in the report in order to mitigate for any loss of agricultural land and soil disturbance as a result of this development proposal.

Sustainability and Sustainable Construction 5.68 General suitability and sustainability considerations have already been identified in the preceding sections of this document. Whilst specific detailed design and construction elements will be identified at subsequent stages, the proposed development will be specified and built to a high standard of construction, commensurate with the applicable national regulations and standards, this will have regard to the following specific elements:

• Energy (including Insulation standards, space heating, limiting the risk of summer overheating, air tightness, lighting and appliances)

• Water Consumption

• Materials Procurement

5.69 This will ensure compliance with relevant national planning policy and guidance, and the adopted Wiltshire Core Strategy.

Waste Management 5.70 A Site Waste Management Plan (SWMP) will be developed at the Reserved Matters stage, and will be utilised during construction to maximise the recycling and reuse of materials, and minimise the amount of waste sent to landfill. Provision of suitable areas for the storage and collection of waste will be considered with the detailed design at the Reserved Matters stage.

22 Conclusion

5.71 Overall the proposals represent an integrated approach to development that addresses the economic, social and environmental themes of the NPPF (as well as relevant Planning Policy) and will ensure the delivery of ‘sustainable development’.

5.72 Whilst the Development Plan may be the starting point for determining this planning application, the Development Plan for Wiltshire is not fully up-to-date (as whilst a minimum housing requirement has been identified there are not up to date housing allocations and settlement boundary policies in place for Westbury as these will be determined through the emerging Site Allocations DPD) and therefore the Paragraph 14 presumption in favour of sustainable development is applicable.

5.73 It is clear that there are no adverse impacts of granting planning permission which would significantly and demonstrably outweigh the benefits of the development – this is the key test of the ‘presumption in favour of sustainable development’.

5.74 The key benefits attributable to the proposed development are:

• The delivery of market and affordable housing, in a highly sustainable location, where the Council is unable to robustly demonstrate a deliverable housing land supply;

• Economic benefits associated with both the (short-term) construction phase and (long-term) occupation phase of the development;

• Increased permeability for the local highway network, including the specific delivery of an off-road, pedestrian and cycle link to the existing trading estate and proposed business park to the north – where currently no link exists or would be deliverable;

• Measures to provide a net enhancement to local biodiversity as a result of development of the site;

5.75 Whilst the negative impacts could be considered to be:

• Limited localised impacts on views and landscape character as a result of development on previously undeveloped land;

• Permanent loss of a small quantity of moderate quality agricultural land, although the land is not currently in agricultural use;

5.76 It is clear that the adverse impacts do not significantly and demonstrably outweigh the benefits, and accordingly planning permission should be granted.

23 6. Planning Obligations – Draft Heads of Terms

6.1 Wiltshire Council has recently adopted a CIL charging schedule and this is therefore now the primary mechanism through which the Council will secure funding to support infrastructure. The Planning Obligations SPD (May 2015) sets out how the Council will continue to use Section 106 planning obligations alongside other mechanisms for securing developer contributions such as CIL.

Community Infrastructure Levy (CIL)

6.2 The required CIL payment is calculated based on net additional floor space measured as Gross Internal Area. As this application is made in Outline with all matters apart from access reserved it is not currently possible to calculate the exact CIL payment that will be required. However, as a guide a CIL liability calculation has been calculated with reference to the indicative dwelling mix set out in the table below, on the basis that the full 145 dwellings were to be delivered on the site.

Market Affordable (30%) (70%)

Indicative Indicative Affordable Intermediate Indicative Indicative Unit Size Total Rent (6%) (16%) Market Total % (sqm) Units 1 Bed 50 7 - 7 5 2 Bed 70 12 6 10 28 19 3 Bed 85 10 3 46 59 41 4 Bed 130 5 46 51 35 Total 34 9 102 145

6.3 Based on the current applicable appropriate charge of £55 per sqm then the CIL liability of the development would be £582,450.00. To be clear this is an indicative figure which would only be confirmed at a subsequent detailed design stage.

Planning Obligations

6.4 In addition to the CIL payment, it is apparent that a number of matters associated with the proposed development will need to be dealt with by planning obligations, secured through Section 106 of the Town and Country Planning Act 1990 (as amended).

6.5 Set out below are the draft ‘Heads of Terms’ expected by Taylor Wimpey associated with the proposed development. It is expected that these Heads of Terms will be refined through the determination of the submitted planning application to enable the completion of the necessary legal agreement(s).

6.6 All contributions will need to be ‘pro-rata’ to reflect the final number of dwellings approved/constructed on the basis of an Outline Planning Permission.

24 Affordable Housing

• 30% provision on-site of affordable housing

• Tenure split to be 80% Affordable Rent, 20% Shared Ownership

• Dwelling mix to be agreed with the Council, although indicative unit mix to be:

Affordable Shared Rent Ownership

1 Bed 20% -

2 Bed 35% 65%

3 Bed 30% 35%

4 Bed 15% -

Public Open Space

Calculated with reference to West Wiltshire Sport and Recreation DPD 2009, based on 2.3 people per dwelling average household size, on site provision for:

Public Open Space • (2.3x145)x16 = 5,336sqm (minimum)

Equipped Play • (2.3x145)x0.5 = 167sqm (minimum)

Transport and Highways

• Provision of off-site highway improvement works to comprise:

• Additional pedestrian/cycle connection to the North on Hawkeridge Road to link the proposed development site, with existing/proposed trading estate/business park;

• Provision of Travel Plan, to include provision of vouchers to households for green travel assistance of £250 per household, or £150 where a household has an occupant entitled to concessionary travel;

Ecology and Nature Conservation

• £109.82 per dwelling required as contribution to Wessex Stone Curlew Project based on recreational impact of Salisbury Plains SPA;

25 7. Summary and Conclusions

7.1 This Planning Statement is submitted on behalf of Taylor Wimpey to support an outline planning application for a residential development of up to 145 dwellings and other associated infrastructure at Glenmore Farm, Westbury.

7.2 The principle of development in Westbury, and the appropriateness and need for development at this Market Town, is established in extant and emerging planning policy.

7.3 Wiltshire Council is unable to decisively demonstrate a deliverable five year housing land supply and therefore the positive benefits associated with housing delivery are given increased importance. Development on this site could be achieved within the next five years and would make a positive contribution to ensuring sufficient housing is delivered in the area, helping to secure and maintain the required supply of deliverable housing land.

7.4 The site represents a suitable location for new development in Westbury, which itself is a sustainable location for future growth to meet economic development and other local objectives.

7.5 The application site at Glenmore Farm, Westbury is suitable for residential development and the application proposal will deliver high quality housing in accordance with the Council’s vision for the area. This is evidenced through the various technical assessment documents that are submitted in support of the planning application, and reflects the integrated approach to securing an economically, socially and environmentally sustainable development that has been pursued by the applicants (Taylor Wimpey).

7.6 The site has excellent access to local employment opportunities and the public transport network, via Westbury rail station, as well as accessibility to the other facilities and services available in the town, including Westbury town centre.

7.7 When considered against the Development Plan and the NPPF the benefits of the scheme clearly outweigh any residual negative impact and there are no specific policies to indicate that development should be resisted in this location (such as Green Belt or AONB). In any event conflict with policies in the Development Plan does not, of itself, constitute harm.

7.8 The proposal will deliver Sustainable Development in accordance with national planning policy, meeting national and local objectives to achieve housing and infrastructure delivery, which accounts for and respects the natural environment and the ability for places to accommodate change.

26

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