Chairman: John Kirkman, Witcha Cottage, Ramsbury, Marlborough, SN8 2HQ Wiltshire Branch Phone: 01672 520429; e-mail: [email protected] Group

E/2011/1139/OUT Care Village on greenfield land alongside Quakers Walk

We strongly support the objections expressed by Town Council and Roundway Parish Council to the development of a care village on the remaining field to the east of of Quakers Walk, south of the new housing development and north of the allotments.

Sustainability The proposed built development would bring to the north-east corner of Devizes an unsustainable extra burden of resident population. Though the residents in the 80-bed care home would probably not be mobile, the 129+ residents in the apartments and cottages would generate movements themselves, and visitors to the whole new community would generate increased traffic. That would predictably worsen the congestion on London Road and the main through-routes, and increase the already illegal pollution levels around the town..

The development would cover for ever an area of agricultural land which, together with the adjoining much-valued Quakers Walk, should preferably be protected as a Special Green Space for Devizes, in accordance with the forthcoming NPPF guidelines, para.130.

Relevant Plans and the Status of the Land In the first sentence of Part 1 and elsewhere (eg Pt 2 para.. 2.2) The Design and Access Statement describes the application site as a “development site”. Use of that expression is misleading. Following the Inspector’s decisions on the draft Kennet Local Plan (see his Report para. 2.236 and 2.244c) the application site is “unallocated land”. It is not designated for anything, nor is it protected from development. This application to create a care village on unallocated greenfield land must be judged against current adopted policies for the area — the Kennet Local Plan 2011 and the Wiltshire and Structure Plan 2016. We contend that the application conflicts with Wilts & Swindon Plan Policy DP1(6): “minimising the loss of countryside and protecting and enhancing the Plan Area’s environmental assets”.

Community Consultation Given the sensitivity of the site, a single, four-hour exhibition of application details was inadequate public consultation. Only 140 households were invited to the meeting via leaflets, only one advertisement was published, only 60 people attended, and only 13 responses to questionnaires were received. This does not indicate the “good degree of support” claimed. Greater efforts might have produced more data about care needs, as well as evidence of local opinion about the relative worth of different potential uses of the site.

Traffic and Air Pollution The well known traffic congestion, air pollution, and parking problems in Devizes would be increased by this proposed development close to the town centre. The Transport Assessment Non-Technical Summary contains assertions based on assumptions that we do not find credible.

What evidence is there to support the claims (para. 5.3) that “each of the service providers will need to make only a single trip to visit all [sic] the residents rather than the present situation where they have to make individual visits to numerous disparate locations”. Will all residents wish to deal with the same service provider?

Again, “all other [car-borne] trips asociated with the care village, for example, visitors; [sic] will already be on the local highway network in order to visit future residents within their existing homes”? Are we really to consider that friends who live on the same street as elderly people, and who ‘pop in’ to see them from time to time are “already on the local highway network”? Will friends and relatives who can comfortably walk or take convenient buses to visit elderly residents currently living in their own homes be happy to use buses to reach the care village, given that “the closest bus stops are on London Road immediately to the north of the site-access junction (para. 4.4)”. None of the drawings provided on the Wilts Council website makes it possible to measure the distance from the bus stops to the proposed care village, but it would be a considerable walk for visitors visiting elderly relatives or friends, especially in inclement weather. The likelihood of most visitors visiting this site using cars to do so is strong.

The Transport Assessment has taken account of the 98 fte employees, but seems not to have considered the traffic impact of medical and other caring staff who will not be employees of the care village but will be frequent visitors. We are not convinced that none of the 129 ‘households’ in the apartments and cottages would have a car; their parking needs and their contribution to traffic should not be ignored.

Need for the Proposed Built Development on the Site Specified We question whether there is need for private care accommodation in Devizes Town to justify building on the site proposed. Also, we would like to be reassured that granting permission would not entail the Council accepting risk of future costs.

The Agenda Papers and Minutes for the Cabinet Meeting on 25th January 2011 include an Agenda Supplement that discusses The Wiltshire Council Older People’s Accommodation Development Strategy (WOPAS), revised version. The Supplement reports (p.26) that the Strategy concludes, inter alia, that in Wiltshire there is:

“A private retirement housing market that is not operating in the best interests of the county. Older people with their future care and health costs are being imported from other areas when they buy into new private sheltered housing schemes, and housing with care models demanded by older people are not being provided”.

The Supplement reports a WOPAS timeline for projects to proceed in the first three years of the strategy because they “address particularly urgent needs in terms of stresses on the system, accommodation that is not fit for purpose or outdated and funding is or is expected to be in place in the very near future (p.35)”. The priority community areas for the early stages of the strategy are Wootton Bassett, Calne, and Trowbridge. Devizes is not included.

The Supplement reports that the Orders of St John Care Trust has purchased a site in Horton Avenue, Devizes to construct an 80-bed nursing and care home for people with dementia. The facility will be completed in April 2013. The residents of Anzac House and Southfields care homes will be relocated to the new facility on Horton Avenue, resulting in the closure of the two existing facilities. One of the former sites will be redeveloped to provide a 45-unit extra-care scheme as part of the joint development framework agreement. It is anticipated that this facility will be completed in April 2015. The other vacant site will either be included within the preferred developer framework agreement, or the capital receipt would be ring-fenced to fund the development programme.

That programme does not seem to reflect urgent need in Devizes.

The Supplement also comments on private-sector developments (p.51):

Successful implementation of the strategy will include working with private sector organisations to ensure that existing and planned facilities and developments contribute to the older people’s accommodation system in a structured and managed way. New private sector development proposals may, for example, meet local needs in communities, making Council-led redevelopment unnecessary. Such proposals may be welcome in that respect but may also expose a potential risk in terms of future costs.

It is therefore appropriate for the Council to take steps to “manage” and influence the market, ensuring that any private sector developments or initiatives which impact on this strategy are monitored and that we work with the private sector as partners in delivering the strategy.

We believe the southern half of the land to the east of Quakers Walk should be left as open green space, not submerged under built development. Additionally, the unusually detailed documents provided with this outline application lead us to suspect that the development would produce exclusive and expensive accommodation, unaffordable to the average inhabitant of Devizes. We are concerned about the “potential risk in terms of future costs” and call for no permission even to be considered for this application unless and until a clear need for it is demonstrated, a clear account is provided and accepted of how the proposal might contribute to the older people’s accommodation system in a structured and managed way, an explanation is provided of how the Council might monitor the development proposed, and the Council is confident that risk would be avoided.

John Kirkman 29th September 2011