Responses to Question 21 – SO5: to protect and enhance the natural environment – Natural Environment – Core Policies 33 - 36 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.

Cross No. Comments Officer Comments Issue Reference Greater emphasis is needed on housing development and the issues surrounding loss of natural habitat. Any new housing needs to incorporate nesting boxes, particularly important for larger scale housing estates. Developers need to be encouraged to produce a wildlife report with their planning application. This is to include apertures between fencing to ensure that native species such as hedgehogs are still able to forage along their natural and instinctive nocturnal feeding routes, some of which cover over a mile in distance. Larger developments (over 25 houses) should have an area reserved for ponds to encourage frogs, toads, newts and other amphibians. Adopted developments CP50 provides the policy basis for requiring all these should be managed with a view to encouraging diversity and Wiltshire Council should ensure that "wild measures as is appropriate to individual developments. areas" are kept aside for this purpose. This could be achieved by depositing grass cuttings in a certain However the core strategy cannot prescribe such area, far enough from the housing to ensure that reptiles such as grass snakes, can breed undisturbed measures in the detail suggested. Such information is Biodiversity and also without causing any alarm to residents. Building houses and caring and protecting our wildlife more appropriate to a Supplementary Planning Document 11 CP50 loss / Water should be as one. Wiltshire Council has an opportunity to be completely innovative and work even more specifically for biodiversity. Management of council abstraction closely with Wiltshire Wildlife Trust and other environmental groups. Every development should be owned developments are also outside the scope of considered as an ecological one and built for that purpose for the benefit of residents and the creatures spatial planning. Policy CP41 and CP68 have been around. Developers also need to include the installation of water butts to each property. Thereby included to ensure water efficiencies are employed reducing the burden on our water supply. The terrible effect which constant development is having on across Wiltshire. our natural water resources, particularly our chalk streams and springs is of major concern. It is too easy to give the go-ahead for another 100 houses without due consideration to just where the water is coming from. Again, each development needs to include a full assessment of where the water will be sourced. Water abstraction has to be an integral part of the planning application. Any negative impact on the rivers, streams, springs and brooks should be a clear sign that the development must not go ahead.

6.5.19 Rural Buffers You say that the Core Strategy does not identify specific rural buffers, but Hilperton Rural buffers were not included due to the provisions and is mentioned. I would not like to think that buffers for North Bradley and Southwick could be overlooked. requirements of PPS7. Country parks have been 115 Trowbridge Rural buffer Core policy 35 Green Infrastructure No mention appears to be made of the Country Parks as part of the included as part of the GI network under CP53 and in the network. Is this an oversight or deliberate? GI strategy at a later stage.

There is no direct reference to landscape, the natural environment and bio-diversity - although these do not easily fall within the term "infrastructure" direct reference to them should still be provided as they are CP50 and CP51 refer directly to landscape, the natural Landscape / 143 critical factors often protected by national statutory designations. This may vary from on site protection, environment and biodiversity. biodiversity new landscaping, off site provision or support or may even be of such importance that development should not occur or should be significantly scaled back to ensure suitable protection. Cross No. Comments Officer Comments Issue Reference There needs to be more specific consideration to the fact that this area sits within the protected landscape of the North Wessex Downs AONB. Although no strategic housing allocations have been proposed into the AONB, which supports national guidance, further comment should be provided on how the 441 houses will be provided without damaging and lasting impact on the AONB through the need for The potential visual and landscape impacts of greenfield site releases. For example has the Council assessed its SHLAA and is confident that the 441 unallocated development will be dealt with through design figure can be met without the need for greenfield site releases? If so this should be confirmed in the statements and on a case by case basis as necessary, Core Strategy. Alternatively if this is not the case how is the Council going to reconcile the potential and subject to the requirements of CP51. Further Landscape / 147 SO6 release of greenfield sites whilst not impacting on national guidance that seeks to conserve and enhance greenfield sites may be identified through the AONB the AONB. This is particularly important in the Marlborough area as there are little or no greenfield sites neighbourhood planning process or a site allocations left that if released for housing would not cause lasting damage to the AONB. Further specific reference DPD, which would be subject to a landscape should also be made to the Avebury WHS and its OUV. For example some of the most recent assessment. Avebury WHS is addressed in CP69 development to have occurred in Marlborough is visible from the Rideway area within the Avebury WHS. Further greenfield site releases around Marlborough may therefore extend the visible impact of the settlement deep into existing protected parts of the AONB and WHS.

The North Wessex Downs AONB support reference to the AONBs within Core Policy 34. Without To meet the requirements of Section 85 of the CROW duplicating existing Government advice it would be beneficial to add that it is a requirement through the Act, Wiltshire Council is statutorily obliged to take into CRoW Act 2000 that "In exercising or performing any functions in relation to, or so as to affect, land in account the objectives and purposes of AONBs in its 155 an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of policy formulation, however to repeat this from the CRoW AONBs conserving and enhancing the natural beauty of the area of outstanding natural beauty..." This would Act would duplicate national legislation - contrary to help re-inforce the need for the statutory protection of the AONBs and recognition by Government of the PPS12. AONBs also receive protection under PPS7 / AONBs highest level of landscape protection. draft NPPF.

There is little evidence of the role of the European Water Framework Directive, (except in para 5.4) which is a critical factor in promoting improvements in the condition of our rivers. Recommendation: that Comments noted. Reference to European Water the European Water Framework Directive be listed as part of the legislative framework of this Topic The framework Directive to be included in Table 1 Paper makes relatively little reference to Wiltshire’s rivers. Under the Wiltshire Biodiversity Action Plan (International/European legislation) in Topic Paper 5. (BAP), it is stated : “ Much of the Salisbury Avon and River Kennet are nationally and internationally CP68 addresses all WFD requirements while CP41 also important for wildlife, however all of our rivers form important wildlife corridors across our county. Many addresses water effeciency. Wider issues of existing Water have suffered canalisation and degraded water quality over the years; however this is now beginning to 228 SO9 levels of over abstratction are more appropriately abstraction / be reversed, although climate change and increasing populations are likely to put new pressures on our addressed by EA licensing and Thames Water’s Water WFD / GI rivers.” This might be read as complacent and should be strengthened to state (at least for the Kennet) Resource Management Plan. Rivers are identified as part that “ the problem of over-licensing and over-abstraction of the Kennet has yet to be solved, and of the green infrastructure network in the WCS and their pressure needs to be maintained on Thames Water and the Government to agree on the funding role will be discussed further under the Wiltshire Green necessary to access other sources of water to meet Swindon’s demand.” The Paper rightly stresses the Infrastructure Strategy. importance of ‘Green Infrastructure’ and wildlife corridors. It should give greater emphasis to the value of rivers as natural green corridors. Wiltshire has a limited supply of brownfield land for development and some greenfield development is Greenfield CP33 – How can this be delivered when you are planning to build upon green space and damage unavoidable to meet the county's requirements. Where 263 development / natural habitat. Greenfield development is unavoidable the least sensitive Biodiversity sites are chosen where possible and masterplans influenced by site proformas.

293 Fully support Core Policies 35 & 36. Support for GI polices noted and welcomed. GI

The Cotswold Canals Trust believes that Key Diagram 4.1 should incorporate the canal network as an A specific canal policy is to be included in any future 294 essential element of green infrastructure. In Core Policy 3, the canal network should be treated as Level Canals revisions of the Core Strategy. 2 Essential infrastructure. Cross No. Comments Officer Comments Issue Reference

The provision of infrastructure should include all green infrastructure relating to the necessary provision of associated open space (including that required for formal and informal sport and recreation), strategic landscaping, amenity spaces, non strategic amenity and recreational spaces including corridors and Wiltshire Council will be progressing potential biodiversity "landscape scale" "receptor" sites for the targeting of "off setting" i.e. the off setting of the impacts of offsetting schemes through consultation with development on bio diversity. This new approach towards valuing eco system services and off setting stakeholders, our communities and potential offset impacts resulting from development is set out within paragraphs 2.28 -2.42 of the Defra White Paper : Conservation 356 providers over the coming months / years, however this is The Natural Choice: securing the value of nature (June 2011). The Environment Bank Ltd in association Credits as yet an untested approach to ecological compensation with the Wiltshire Wildlife Trust and others has already established a pilot project - The Thames in the UK and has no national policy framework or Headwaters Conservation Credits Pilot, part of which extends to cover Wiltshire. The principle of guidance. "Conservation Credits" should be applied in appropriate circumstances where development proposals can facilitate off setting of development impacts and resultant pooled credit purchase value targeted at identified receptor site. For more information go to www.environmentbank.com

The potential for off setting via the "Conservation Credit" principle and the opportunity to identify landscape receptor sites is alluded to at paragraph 6.5.4 - 6.5.6 and is welcomed. It is nonetheless understated in terms of the significant potential funding sources for bio diversity and eco system Wiltshire Council will be progressing potential biodiversity enhancement which could arise through a co-ordinated development management process. There offsetting schemes through consultation with should be a specific policy created within the Core Strategy related to off setting and the application of stakeholders, our communities and potential offset conservation credits. This is justified on the basis of the potential scale of financial advantages Conservation 359 providers over the coming months / years, however this is (particularly during an era of public finance restraint) for funding nature conservation and need to Credits as yet an untested approach to ecological compensation achieve policy application consistency sufficient to achieve the development industry's in the UK and has no national policy framework or support. Environment Bank Ltd is already engaged in assessing development projects across the UK guidance. applying Defra metrics used to calculate off set values etc. Wiltshire, with such a diverse and potentially habitat rich landscape should take full advantage of this new approach to development impact mitigation.

Core policy 33 1. local sites The policy is very subjective. Bullet points i-iv are open to interpretation, leaving local sites vulnerable. The wording 'reasonably', 'as far as possible' and 'where appropriate' are not clear. Definition of 'planning considerations in the public interest' is a matter of opinion. Accommodating development is apparently in the public interest meaning that conservation interest can be ignored. Therefore the policy is meaningless if the only sites proposed are damaging. What constitutes 'appropriate compensation measures' is also open to interpretation. Achieving developer compensation for environmental mitigation is not a priority in the hierarchy of infrastructure in Core policy Wording of CP50 to be carefully considered; 3, and lack of funds may leave mitigation unlikely to happen. Previous 'appropriate compensation environmental mitigation for individual sites does not measures' have proved to be inadequate in my experience. E.g. measures to protect a roost of lesser Biodiversity 458 CP3 qualify as 'infrastructure' and therefore cannot be horseshoe bats, at the Drews Park development looked impressive on paper but failed, despite being loss included in CP3; appropriate compensation measures overseen by conservation bodies. Complex issues involving the effects of development and mitigation on must be determined on a site by site basis. ecosystems seem to be poorly understood. In my experience decisions are clouded by persuasive developers forwarding convincing reports written by paid consultants who lack knowledge of the local area and specific conditions. Adverse impact from trampling, pet predation, disturbance etc have not been considered important enough to warrant mitigation, and have resulted in damage at Drews Pond Wood LNR from recent housing development. What process will be in place to determine independently what is meant by 'appropriate compensation measures' to ensure that effective results are actually achieved? Core Policy 35 – Green infrastructure: This has the Parish Council’s support, in particular the importance 477 Support for GI policy noted and welcomed Canals of the Kennet and Avon canal and the rights of way to the parish. The text states that we will undertake to produce a single Landscape Core Policy 34. Landscape Assessment. North Wiltshire LCA (2004) is well out of date in terms of recent set of guidelines SPD that pulls together all the LCAs for 492 character developments around Malmesbury. It has doubtful relevance in respect of the 2011-2026 plans. Wiltshire. No housing sites have been identified at assessment Malmesbury through the Core Strategy. Neighbourhood Cross No. Comments Officer Comments Issue Reference plans or any site allocations DPD for the area will be supported by up to date landscape assessment work.

The Canal Partnerships ( Cotswold, Wilts & Berks) in supporting Policy 35 would like to suggest that a more robust policy statement is made about the canals to protect the alignment of these restoration schemes to replicate existing District Council Local Plan policies. The current proposal for the new route Wilts & Berks Canal in Melksham (the Melksham Link) should be protected. It would be useful to further A canal specific policy (CP53) has been included in the 568 Canals define the Canal Network as the operational Kennet & Avon Canal and the restoration schemes for the pre-submission draft. Thames & Severn and Wilts & Berks Canals To enable delivery of the canals as part of the Green Infrastructure there should be clarity that the restoration and enhancement of the Canal Network is supported by Core Strategy policy to enable funding from Community Infrastructure Levy

The majority of ancient woodlands (i.e. All over 0.5ha) are designated as Local Sites and will therefore be protected Comment No 618 by Justin Milward (ID. 549174) in all but exceptional circumstances (CP50 (1)). Ancient woodlands under 0.5ha will be protected as BAP habitat under CP50 (2). PPS9 / draft NPPF also afford strict protection to ancient woodland which should not be Ancient 618 Please see website below for full comment. repeated here. The level of statutory and policy Woodland protection for ancient woodland is accepted and wording of policy CP50 reflects and is consistent with all of that referred to by the consultee. The examples given of "good LDF wording" are too detailed for the Wiltshire http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 Core Strategy. Such detail could be addressed in a Biodiversity SPD.

Comment No 619 by Justin Milward (ID. 549174)

Strategic level GI will be identified through data analysis 619 Please see website below for full comment. and stakeholder participation, to be clarified in the Woodland forthcoming GI strategy.

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 Cross No. Comments Officer Comments Issue Reference Core Policy 33 supported Core Policy 34 iii) Add "through the delineation of highly valued landscapes.". Reasons a) Unless these areas are to be delineated in LDFs/Neighbourhood Plans there will be endless arguments as to what or how much is protected. b)para 6.5 19 only says aspects of landscape character have to be considered and this does not give full protection. c)It is not stated that landscape character assessments or the quality of the agricultural land has been assessed in all the urban fringe areas where Rural buffers or local landscape designations were not development is proposed. d) Since the draft RSS when there was temporary absence of rural buffers included as they are contrary to the provisions and there have been applications for large sites to the west of Swindon. This shows that the countryside 662 principles of PPS7. Previous EiPs demonstrate that rural Rural buffer policies are not strong enough in themselves. 6.5.18 6.5.19 It is evident from recent applications for buffer policies are likely to be unsound. GI standards will land to the West of Swindon that the rural buffers are need ed for urban fringes of principal towns. There be included as an appendix to the Core Strategy may be a name change to highly valued landscapes. The areas of countryside between the principal towns and settlements or countrdyside in need of special protection are so narrow that in order to protect them, no development should be allowed, other than as for green belts. . Core Policy 36 Green Infrastructure Wiltshire Green Infrastructure Standards need to be incorporated in the core Strategy so they can been seen and consulted on. It is important for members of the public to know what they area.

We welcome the measures set out in CP 33/3 to protect our European Sites from harm. The Habitats Regulation Assessment clearly reaches no conclusion of 'no likely significant effect' of the plan in respect Support welcomed. Consultee recommendation is also of predicted increase in recreational disturbance, and we accept the mitigating measures set out. It referred to in the HRA (Para 3.2.14). We will consider 683 should, however, be stated that the measures required in CP33/3i are beyond those required to achieve CP3 Biodiversity where in the WCS document it is more appropriate to favourable condition. We welcome and support the Council's proposal to raise revenue for these take this forward. measures through the Community Infrastructure Levy in appropriate areas and recommend this is specifically referred to in the Policy.

CP33/2. Ecologically sustainable development - Development proposals will need to demonstrate how they protect features of nature conservation and geological value as part of the design rational Detail about green infrastructure will be required in recommend should read: 'Development proposals will need to demonstrate how they protect features of accordance with CP52 and it is inappropriate to duplicate nature conservation and geological value as part of the design rational and Green Infrastructure that requirement under CP50. Agreed that currently the Biodiversity 684 Strategy. CP35 Green Infrastructure: Recognition should be made of the potential to create and enhance References to landscape scale projects have been loss chalk grassland links (a biodiversity corridor) between the AONBs of Cranborne Chase & West Wiltshire strengthened. Strategic level GI will be identified through Downs and the North Wessex Downs, incorporating the designated sites on Salisbury Plain and Porton data analysis and stakeholder participation, to be clarified Down. This has long been recognised by the biodiversity partnership in Wiltshire as a key opportunity to in the forthcoming GI strategy. enhance Wiltshire's natural environment.

Special Landscape Areas Paragraphs 6.5.14 - 6.5.15 We support the decision not to include Special Landscape Areas in Policy 34 , and the proposed move to a criteria based policy approach to landscape Existing policy on SLAs will be retained until such time as Special 692 protection, with reference to the Landscape Character Assessments for the county, in line with national an evidence based decision on their long-term use can landscape planning policy PPS7. We concur with the Council's reasoning, as set out in paragraphs 6.5.14-15: - a be made. areas poorly defined and understood network of Special Landscape Areas is not helpful to good planning.

This policy includes the following text:-- A number of key priorities for the enhancement of the strategic GI network in Wiltshire include: • The delivery of the Cricklade Country Way Green Infrastructure Strategy; • The continued restoration and enhancement of the canal network in Wiltshire; Comment:-- A specific policy for canals (CP53) has been included in 703 To be able to deliver an element of the second priority the strategy needs to SPECIFICALLY note that Canals the pre-submission revision. planning powers will be used to ‘protect the continuous route' of the Wilts & Berks Canal restoration. Note:- The continuous routes of the Kennet and Avon Canal, and Cotswold Canals do not currently require this protection as they are already in the ownership of a single operating body. Cross No. Comments Officer Comments Issue Reference

Core Policy 35 Green Infrastructure The Kennet & Avon Canal is one of the most important lengths of Green Infrastructure in Wiltshire and is the most important in West Wiltshire. The increasing numbers of all types of users of the canal is putting huge pressure on the environment of the canal corridor. Wiltshire Consideration of this issue has been given in a canal 730 Council must have a policy which will ensure that the long-term development of the canal is carried out Canals specific core policy so that the environment of the canal is not damaged, is sustainable and complies with the planning conditions that apply in the West Wilts Green Belt and the Cotswold AONB. Wiltshire Council should adopt a policy regarding residential boats on the canal similar to Policy HG14A adopted by B&NES.

I agree completely with the statement about green infrastructure, but the plan does not see to include The core strategy establishes the minimum requirements any positive plans for the development of any in Devizes other than to screen a proposed new for GI, however spatially specific needs and issues will be 757 development. People (particularly children need open space for recreation. Such spaces must be addressed through neighbourhood planning and the planned alongside new developments and must be more than a play area for the under sevens! forthcoming Wiltshire GI strategy.

This is pure orwellian stuff. This is a Council that proposes to build indiscriminately and unnecessarily across greenfield sites; this is a council that tried to ram a road through one of the most important landscapes and habitats in southern England; this is a Council where officers and councillors can be heard to say "Oh bats don't count for anything in our plans"; this is a council that encourages a huge Greenfield 788 Comments noted megashed development visible from the World Heritage site of Stonehenge. There are good people in development the Council who probably want to see the concerns for the environment expressed here realised in practice. The problem of a lack of care for the County's landscape, heritage and habitat, however dominates at a higher level and persists.

The notes below are explored further in our main submission available as a separate document The Showell Protection Group believes there is a major inconsistency between the policy and proposed implementation proposals as outlined in 5.1 Chippenham Community Area Strategy The Wiltshire Core Strategy Document Core Policy 2 states the intention that ‘ At least 35% of development will take place on previously developed land’ . Whilst it is recognised that this is a County wide target it is noted that all of the proposed Showell Farm development is on greenfield land. Whilst it is conceivable that this would be ‘balanced’ by other brownfield site development elsewhere in the County it is certainly not in the spirit of Core policy 2. The UK, and indeed the wider world, is now much more aware of the environmental Greenfield 952 implications of planning than in previous times. Safeguarding green spaces, protecting food supplies, Chippenham Comments noted. development limiting the carbon footprint etc., are all top of the agenda in planning. Regeneration and recycling of existing brownfield sites should therefore be the prime goal of every planning exercise. Currently there are many vacant business sites around Chippenham that have the potential for redevelopment. There may of course be some scope for a change of use at some sites. For example, a mixed use development at Langley Park seems possible, but for many other sites a change of use seems far less appropriate and imaginative schemes need to be created to rejuvenate these areas. For example, there is a long standing commitment to open up a second entrance to Bumpers Farm which has the potential to overcome one of the current key concerns of existing tenants. This policy mentions the canal network. Previous Local Plans had specific policies to protect the historic route of the Wilts & Berks. This should be carried into the Core strategy. There should also be a route for A specific policy for canals (CP53) has been included in 953 GI Canals a new Melksham Link route into the town centre from the proposed junction with the Kennet & Avon the pre-submission revision. Canal at Semington. Cross No. Comments Officer Comments Issue Reference

Comment No 1038 by Jenny Hawley (ID. 549562) Wording of CP33 has been reconsidered in drafting CP50. Re: reference to AONB management plans in each of the relevant CAs - to be included. Re GI, rivers Biodiversity 1038 Please see website below for full comment. and other habitats such as woodlands are component of loss / AONB / "sub-regional green corridors" which will be identified by GI the forthcoming Wiltshire Green Infrastructure Strategy through data analysis and stakeholder participation. http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011

Core Policy No. 35 Green infrastructure The rights of way network in the Devizes are, including the footpaths adjacent to highways are extensive. If people are to be encouraged to leave vehicles at home, Point noted. This will be a matter to take up with the 1067 then these footpaths are rights of way must be maintained to a level where they are safe to use. This is SO8 Highways dept through the Clarence phone line and Rights of way especially important with footpaths alongside A class roads, where bad maintenance can reduce the through the Rights of Way Improvement Plan. width to a dangerous level.

We have reviewed the documents and believe that the Core Strategy has not adequately demonstrated that it will not have a likely significant effect on the Bath and Bradford on Avon SAC, and the River Avon SAC. Natural England's advice is that the Wiltshire Core Strategy is thus not legally Natural England's comment in relation to the SACs and 1073 compliant, and is currently unsound. We are also concerned that the Council has not demonstrated landscape have been noted and addressed in revising HRA that it has adequately considered the impacts on designated landscapes in writing its policies. As a the plan result it has not discharged its duties to have regard for the purposes for which the AONBs were designated, nor justified the rationale for its policies, and that the policies may be unsound .

Suggested amendment to 6.5.1 accepted, new paragraph to be added before "Biodiversity and Geodiversity" heading. Details of how a developer should go about Comment No 1109 by Charles Routh (ID. 382216) demonstrate that biodiversity enhancement has been considered appropriately are too detailed for the core strategy. LVIA is a DC issue rather than policy. LVIA are Biodiversity required for EIA applications and major developments BD / loss / that are likely to have significant landscape & visual 1109 Please see website below for full comment. Landscape / landscape effects. It is therefore difficult to prescribe and advice is to GI character consult planning officer to check requirement 2. assessment Suggested policy text change is repetitive 3. The text comments: "Planting regimes ..." http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 "Developments should embrace ..." to be included. Comments on 6.5.21 and CP36 This part of the policy refers to onsite GI - to be clarified in the pre-submission revision. Cross No. Comments Officer Comments Issue Reference

Draft Topic paper 5 - Natural environment This topic paper gives a good overview of the current natural environment policy context in Wiltshire. There is however one aspect of the natural environment It is not considered appropriate to identify individual which it might have been useful to draw out, namely the perceived current areas of policy failure, i.e. developments as poor examples within the public examples of development where inadequate policy has led to sub optimal natural environment domain, however specific cases where policy may not 1113 outcomes. Whilst we are aware of a number of these (and have used them to illustrate policy been fully applied or mitigation implemented have been modifications) a more considered collation of these would be appropriate. The topic paper also serves to collated and widely discussed by Wiltshire Council illustrate a significant structural weakness when considering the natural environment. This is, that officers in formulating this policy. A scheme to monitor the broadly, there is very little monitoring of how development affects the natural environment. It would, impacts CP50 will be implemented. perhaps be helpful if this were acknowledged, and proposals put forward to address this.

Comment No 1115 by Charles Routh (ID. 382216)

The draft vision, objectives and open space standards have been circulated among stakeholders for further comment and will be included in the pre-submission draft 1115 Please see website below for full comment. for public consultation. The final vision and objectives will also be subject to further full consultation through events as part of the forthcoming GI strategy.

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011

3.1. Core Policy 34 - Landscape (p.144) 3.1.1. We object to the omission of a bullet point referring to the archaeological and cultural ‘landscape without parallel' of the World Heritage Site and to the WHS Reference to the WHS management plan to be 1159 SO6 Management Plans. 3.1.2. There should be a heading in the section relating to this Core Policy that considered in CP51 mentions the WHS and refers readers to the section on WHSites later in the Core Strategy.

The management of river water resources is undertaken by the Environment Agency and water companies and who are advising the Council on water efficiency measures that need to be included in the core strategy. Do not deal robustly with the problem of over abstraction. Funding has to be found to access other Effects of development in Swindon on the Kennet are Water 1174 sources of water for Swindon as the kennet river will be exhausted. Wiltshire council should actively CP50 being considered by Swindon Borough Council in its core abstraction encourage to respect the fragility of our natural environment. strategy. EA and Thames Water have not raised water resource issues as a concern in relation to proposed development in the Kennet catchment. CP41 and CP68 address water efficiency in new development. Cross No. Comments Officer Comments Issue Reference

Topic paper NO 5 and Strategic objective SO5 and SO10 so not deal robustly with the problems of over abstraction I the upper Kennet and ARK recommends these should be strengthened to say " the problem of over licensing and over abstraction of the Kennet has yet to be solved, the pressure needs to be maintained on Thames Water to access other sources of water and meet surplus demand." ARK welcomes measures to promote sustainable WHAN drainage systems. The water framework directive and its requirements are not given sufficient priority. ARK recommends that the European water See comments for 1174 in relation to abstraction in the Water 1185 framework directive be listed as part of the legislative framework in the topic papers and that Wiltshire CP50 kennet. WFD is addressed in CP68. abstraction council gives a commitment to play an active part in delivering the catchment plan for the kennet. ARK recommends greater emphasis should be given to the value of rivers (particularly of the kennet) as natural green corridors. In general ARK would strongly endorse the overall approach proposed in the conclusions that "sustainable development in Wiltshire must be encouraged in a responsible manner which respects the importance and fragility of our natural world "and that all stages of decision making are informed by relevant ecological information".

Pressure has to be applied to Thames Water and the Government to stop or substantially reduce the extraction of water in the Kennet. In these times of lower rainfall the river Kennet is being killed along Comments noted, however the Core Strategy cannot 1190 with the natural habitat and creatures/fish as the flow and depth upstream of Kintbury are insufficient to CP50 influence national government or resource management support the river we know and love. We owe it to future generations to retain in good condition one of the plans for the wider Water Resource Zone. few remaining chalk streams in England. 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 Swindon will also be linked to the Thames at Abingdon by the Wilts & Berks. A very considerable amount of work has been carried out on these waterways largely by labour and professional input by volunteers. I am concerned that, while the Wilts & Berks Canal Partnership includes both Wiltshire and Oxfordshire counties, the historic and proposed new alignments of the canal are not protected in the Core Strategy. Two major sections, the Wichelstowe route south of Swindon and A specific canal policy (CP53) has been added to the 1299 Canals the new link from Semmington to Melksham are in advanced stages of construction or detailed planning. Core Strategy. 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 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. Cross No. Comments Officer Comments Issue Reference

Wider landscape and heritage matters are dealt with under CP51 and CP58 and it would not be helpful for development management to have a combined policy. Sites of national and international importance are protected under national legislation and covered by Comment No 1463 by Richard Burden (ID. 556113) existing and forthcoming National Planning Policy. In relation to former CP33/3 it will not be possible to comply with the Habitats Regulations 2010, if we do not include a AONB / BD / strong and specific policy to demonstrate how Landscape 1463 Please see website below for full comment. Landscape / recreational pressures will be offset. Re: former CP34 - Character GI suggested amendments and supporting text have been Assessment considered; the duty under the ELC is addressed in the Topic Paper and discharged by CP51; definitions of setting have been expanded; GI cannot be used as a http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 local landscape designation. The three AONBs have been consulted specifically on the draft GI vision and objectives and will be involved throughout the process of producing the forthcoming GI strategy. The need for an overarching concept for CP52 is noted.

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 first paragraph states that the policies were not saved because they were considered to conflict with national planning policy, the Government has now said they would protect highly valued landscapes. E.g., after Greg Clarke's statement in the House (which was used in evidence at the Hook Street 175 house development appeal) the value of Landscape assets will be valued and protected through landscape and areas of special importance was upheld. We support the need to protect the landscape, 1477 CP51, while the distribution of development will be as well as the uniqueness of individual settlements, both of which the Core Strategy recognises to be controlled through the settlement strategy. prized objectives by the local community. It is important for this strategy to be taken forward by appropriate and strong policy mechanisms. Housing growth in the main settlements to improve their vitality and create a critical mass to deliver improvements in infrastructure is necessary. However, given that there are a number of existing outstanding housing commitments, future 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. 1478 We request that the Wiltshire GI standards in Policy 36 are added to the Core Strategy. Standards have been included in the core strategy Cross No. Comments Officer Comments Issue Reference CORE POLICY 34 III) Insert: ‘Through the delineation of highly-valued landscapes, formerly known as rural buffers in policies in LDFs/Neighbourhood Plans. It is essential that there is a delineated protection, to avoid arguments re actual protected area and separate identities at appeals, inquiries etc Although para 6.5.19 states aspects of landscape have to be considered . That does not give full and appropriate protection Following the introduction of open countryside policies and the absence of rural buffer policies the area to the West of Swindon we have seen applications for thousands of housesbeing submitted. It Rural buffers and local landscape designations were not is suggested that the Core Strategy needs to delineate highly valued landscapes and that the policies included as they are contrary to the provisions and are stated and areas mapped in the LDFs and Neighbourhood Plans. It should be pointed out here that, requirements of PPS7. Previous EiPs demonstrate that 1514 although the first para states that the policies were not saved because they were considered to conflict Rural buffer rural buffer policies are likely to be unsound. GI with national planning policy, the Government has now said they would protect highly valued standards have been included as an appendix to the landscapes, e.g. after Greg Clarke's statement in the House (which was used in evidence at the Hook Core Strategy Street 175 house development appeal) the value of landscape and areas of special importance was upheld. The point is made clear from the attached maps which show the erosion of the rural buffer from 2001 to 2011. Unless we have a clear area, which is firmly protected, there will be no demarcation line. The strip is narrow and is in need of firm and clear protection. CORE POLICIES 35 AND 36 GREEN INFRASTRUCTURE Suggest that the Wiltshire GI standards in policy 36 need to be in the Core Strategy so that all may see.

Devizes and other towns will have the opportunity to 6.5 SO5: to protect and enhance the natural environment This section focuses on specific areas that identify and protect important areas of green space have been previously identified. It fails to recognise that incremental urban sprawl, as towns grow through the neighbourhood planning process, as through piecemeal developments , can destroy their natural environment and character. Devizes has identified in the recent White paper and draft NPPF. It is 1569 been allowed to grow outwards for decades with no thought for the preservation of green space. There is Devizes Green spaces more appropriate for local communities to identify such now a serious lack of public open space and green space. There is a need for areas to be preserved as spaces at the neighbourhood / town scale rather than future parkland, even if the funds to create parks are lacking at present. It may also be possible to through the Core Strategy. It is not feasible to establish a establish a green belt to prevent continued urban sprawl and the merging of communities. Green Belt around Devizes.

Core Policy 34 – Landscape Bradford on Avon Town Council fully supports this policy – in particular the need to protect the landscape setting of the town and the skyline. Core Policy 35 – Green infrastructure A specific canal policy has been added to the Core 1583 Canals Bradford on Avon Town Council fully supports this policy – in particular the need to protect the canal Strategy (CP53). network.

I have looked at the Core Strategy Consultation Document and I am most concerned that the Wilts and Berks Canal Restoration Project is not very prominent and therefore is easily missed. I should be A specific canal policy has been added to the Core 1617 Canals grateful if you would consider raising its profile in the document so that users of the document will not (in Strategy (CP53). error) compromiseits restoration

I have been a member of the Wilts & Berks Canal Trust for 20 years and have been delighted at progress especially over the last few years. This has come about through support of, among others, A specific canal policy has been added to the Core 1631 yourselves. So I am surprised and disappointed to hear that Spatial Planning Policy makes no mention Canals Strategy (CP53). of the Wilts and Berks canal. It needs both its historic route and any new routes such as at Melksham included so they are protected. I trust this will be included before the document is finalised. Cross No. Comments Officer Comments Issue Reference Sport England is aware that this informal round of consultation seeks to gather the views of local communities, stakeholders and statutory consultees on the scope and content of the draft Core Strategy document. Our main concern at this stage is in relation to the evidence base for sport and recreation. Evidence Base / Topic Papers In relation to the evidence base to support the emerging Wiltshire Core Strategy, I note that Paragraph 1.18 states: “The Core Strategy is based on robust evidence about the challenges facing Wiltshire and the best and most realistic ways of meeting those challenges. This evidence has been gathered from a variety of sources, including commissioned studies.” Paragraph 1.19 also explains that: “A series of Topic Papers have been produced, which collate the evidence in a comprehensive manner. These will continue to be developed following consultation, taking into account the response and will be finalised to support the publication of the draft Core Strategy.” However, there does not appear to be any reference to an evidence base for sport and recreation. Sport England’s view is that, in order to meet the requirements of PPS12 and PPG17, this should include a strategy covering the need for indoor and outdoor sports facilities, including playing pitches. It is understood that the Mapping to meet the requirements of PPG17 is ongoing Council has already undertaken work on producing a Leisure Facility Strategy which proposes significant and will be used to update the evidence base to support 1661 changes to current provision, based on a wide range of research. Sport England has worked closely with the core strategy policies on open spaces provision Green spaces Wiltshire Council over the last 2 years in relation to this work. However, we are concerned that there is (Green Infrastructure). Local plan policies on sports not currently a ‘Topic Paper’ covering sport and recreation - a large amount of work has already been facilities would be saved. undertaken which needs to be reflected in the Core Strategy, particularly within the individual sections relating to each of the 20 Community Areas. Assessment of Playing Pitch Needs In addition to indoor sports facilities, we are aware that a number of the former District Council’s in Wiltshire (eg North Wilts, Kennet) undertook detailed assessments of the need for playing pitches in their areas, and produced comprehensive Playing Pitch Strategies, in line with the recommendations of PPG17. We consider that an assessment of playing pitch needs in Wiltshire is required in order to support effective planning policies and to set locally derived standards of provision, as required in PPG17. I trust that the above comments can be taken into account prior to the production of a draft Core Strategy. In the absence of the above supporting evidence work being undertaken, Sport England does not consider the emerging Core Strategy would be ‘sound’. We consider that it needs to be clearly demonstrated that the proposed policies are founded on a robust and credible evidence base for both indoor and outdoor sports facilities, including playing pitches. In response to paragraph 6.5.16 and 6.5.17 that relate to the designation of green belts. We accept the importance of the Western Wiltshire Green Belt allocation and its objectives to maintain the open character of undeveloped land adjacent to Bath, Trowbridge and Bradford-on-Avon. However we would propose a minor amendment to the boundary of the existing green belt on the edge of Colerne. The In accordance with PPG2, Green belts are only to be attached plan shows the area we consider should be removed form the Green Belt allocation (edged in altered in exceptional circumstances. The Core Strategy red). The reason for removing the land from the Green Belt allocation is to enable more opportunity for studies have no identified the need for any strategic further development to take place on the edge of Colerne. Colerne is identified as a larger village which CP1 / 1689 development at Colerne which would justify such an Green belt can accommodate additional development in the future in order to meet the community needs but the Corsham alteration to the Green belt boundary, and indeed such allocation of the Green Belt will restrict this. The village is currently abutted by green belt designation development is likely to conflict with the settlement along the southern and western extents of the village. The removal of this land from the green belt strategy for small villages. allocation will not conflict with the overall aims of the green belt policy as we do not feel it will significantly affect the open character of land adjacent to Bath, Trowbridge and Bradford-on-Avon. The area identified is closely related to the existing village, it is defined by the main roads which lead to the village and some of the existing village services (allotments) lie within the area identified. No development has been allocated at Malmesbury Core Policy 34. The North Wiltshire Landscape Character Assessment and possibly the other LCAs through the Core Strategy, however neighbourhood plans Landscape generally do not fully describe the relationship between the countryside and urban environments. In the 1726 Malmesbury or site allocations DPDs which do identify such sites will character case of Malmesbury in particular this relationship forms an important part of the town’s character and need to be supported by up to date landscape assessment needs description so development can be framed around it. assessments for the town. Cross No. Comments Officer Comments Issue Reference The Core Strategy is produced in a sufficiently flexibly manner to allow these sites to come forward as they 2. There are many large vacant brownfield sites in North Wiltshire, Copenacre, Lyneham Air base, parts become available for development and indeed this is of Bowerhill, to name a few, What potential do these sites hold and surely this should help to lessen the supported through CP37, however they do not meet the Greenfield 1732 impact on greenfield development. 3. Our environment is supposed to be a conservation area, and we criteria of a strategic allocation (as set out in our TP 14). development are lucky enough to live here. But if we continually threaten the wildlife and reduce their habitats and Conservation areas will continue to be protected from green space for our children and future generations, what will be left for others who follow us? inappropriate development under saved local policy and national policy.

Comment No 1733 by John Gornall (ID. 550895)

A specific canal policy has been added to the Core 1733 Please see website below for full comment. Canals Strategy (CP53).

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011

Alongside the sustainable construction and low-carbon energy provisions in planning. It is important that any developments are ecologically sustainable and developers protect nature conservation, seek opportunities to enhance biodiversity and meet objectives and targets of the BAP and Nature Map. We support Biodiversity and Geodiversity (Core Policy 33) in particular 6.5.3, 6.5.4 and 6.5.6 and Green Biodiversity 1740 Infrastructure 6.5.20, Core Policy 35. Developments must not cause harm to the amenities of Support for these policies noted. loss neighbouring dwellings and landscape features and settings should be enhanced and integrated into new developments and have regard to aesthetics, function and environmental qualities. It is important to make sure that developers ensure that there are local biodiversity and wildlife corridors incorporated into any new development to maintain and enhance these resources for the future.

The need to protect and BAP habitats is set out in CP50. The level of protection afford to an area must be Comment No 1795 by Kevin Burnside (ID. 550556) proportionate to its ecological value. Not all areas of BAP habitat are of national / county value, but those which are will generally be recognised through SSSI / CWS designation and given stronger weighting under other policies. The mitigation hierarchy must be applied to all Biodiversity 1795 Please see website below for full comment. BoA biodiversity losses. Bradford and other towns will have loss the opportunity to identify and protect important areas of green space through the neighbourhood planning process, as identified in the recent White paper and draft http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 NPPF. It is more appropriate for local communities to identify such spaces at the neighbourhood / town scale rather than through the Core Strategy. Cross No. Comments Officer Comments Issue Reference 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 ARK recommends these should be strengthened to say: "the problem of over-licensing and overabstraction of the Kennet has yet to be solved, and pressure needs to The management of river water resources is undertaken be maintained on Thames Water and the Government to agree on the funding necessary to access by the Environment Agency and water companies and other sources of water to meet Swindon's demand." • The Water Framework Directive and its who are advising the Council on water efficiency requirements are not given sufficieh priority. ARK recommends that that the European Water Framework measures that need to be included in the core strategy. Directive be listed as part of the legislative framework in the Topic papers and that Wiltshire council gves Effects of development in Swindon on the Kennet are Water 1817 SO10 a commitment to play an active role in delivering the Catchment Plan for the Kennet. • ARK being considered by Swindon Borough Council in its core abstraction recommends' greater emphasis should be given:to ,the valve of rivers ', (particulciily the Kennet) as strategy. EA and Thames Water have not raised water natural green corridors: '• ARK welcomes measures to promote sustainable urbim drainage systems • In resource issues as a concern in relation to proposed general ARK would strongly endorse the overall approach proposed in the Conclusions that "sustainable development in the Kennet catchment. CP41 and CP68 development in Wiltshire must be encouraged in a responsible manner which respects the importance address water efficiency in new development. and fragility of our natural environment", and "that all stages of decision making are informed by relevant ecological information ".

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). He is also the onwer of the A.O.N.B site with the Nunton Village. My letter of the 1.04.08 referes. Adjacent land to the Hospital is a "lower grade! and would appear to satisfy your matters if concern re providing the hospital housing. No infringement on the Local Plan,Countryside Policies. Reduce Greenhouse Gases, move travel time 1884 Landscape issues are dealt with under CP51 Landscape and distances. Skilled staff, in the event of disasters, aircraft, railway and serious highway crashes, on site, almost, if needed. I seem to be doing nothing but apologising for the disjointed evdience. The matters and evidence is important to me and I hope yourselves, I hate building on and destroying this A.O.N.B, "beautiful landscape". It is a perminant requirement of your strategy and the "Local 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 management of river water resources is undertaken Topic Paper 5 and SO5 and SO10 do not deal robustly with the problems of over abstraction in the by the Environment Agency and water companies and upper Kennet and ARK recommends these should be strengthened to say 'the problem of over-licensing who are advising the Council on water efficiency and over-abstraction of the Kennet has yet to be solved and pressure needs to be maintained on measures that need to be included in the core strategy. Thames Water and the government to agree on the funding necessary to access other sources of water Effects of development in Swindon on the Kennet are Water 1894 to meet Swindon's demand. The Water Framework Directive and its requirements are not given SO10 being considered by Swindon Borough Council in its core abstraction sufficient priority. ARK recommends that the European Water Framework Directive be listed as part of strategy. EA and Thames Water have not raised water the legislative framework in the topic papers and that the Wiltshire council gives a commitment to play an resource issues as a concern in relation to proposed active role in delivering the Catchement Plan for the Kennet. There should be greater emphasis on the development in the Kennet catchment. CP41 and CP68 value of rivers, particularly the Kennet as natural green corridors. address water efficiency in new development. Cross No. Comments Officer Comments Issue Reference

The policy refers to valuing the character of all landscapes in accordance with the ELC. AONBs are protected through national policy and legislation and the Core Policy 34 Landscape This should be strengthened to include AONB's in the title of the Core Policy. Core Strategy should not repeat that policy. 'Where Development should demonstrate that it does no harm to the landscape, or the other way round! The possible' is necessary as not all development can words' 'where possible' should be removed from the first line. The setting of the AONB should be enhance landscape character and without this phrase the AONB / 1898 defined. 6.5.16 Green Belt We feel this policy has been watered down by not being a Core Policy in its policy becomes unworkable. The setting of an AONB Greenbelt own right as in the past. It is one of the most robust of National Planning Policies and should be given cannot be accurately defined e.g. on a map, however the more prominence than a part of a Core Policy. The Green Belt policy should be strengthened. supporting text has been updated to clarify what is meant by the term ‘setting’. It is agreed that national green belt policies are strong, therefore there is no need to repeat these in LDF documents.

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 research and consultation and it would seem logical to utilise this evidence base in developing the WCS. Linked to this, the Authority would welcome greater clarification over the Council's approach to CP15 will be carried over to the WCS. Setting of the NPA 1900 housing in the Wiltshire-wide plan area, with the consultation document stating that "around 37'000 new is included in CP51. homes" are proposed up to 2026 (para. 3.6). The Authority is aware that Wiltshire Council is currently proposing a housing figure approximately 20% lower than the Secretary of State's Proposed Changes to the South West Regional Spatial Strategy as part of 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. 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 recommendations in this respect, these however, do not appear to have been This will be addressed through future discussions with 1923 HRA addressed in this consultation document. The Authority also welcomes reference to the consideration of NFNPA SANGs (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. Cross No. Comments Officer Comments Issue Reference

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 environment and biodiversity, acknowledge that areas of special landscape such as the Wellhead valley may need continuing The White horse alliance report is welcomed as part of Wellhead 1926 protection in the final Core Strategy. It is good that the Wellhead Valley is singled out for special mention the emerging evidence base. valley in this way. We cannot however welcome 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.

Comment No 1944 by John Webb (ID. 390921)

A specific canal policy has been added to the Core 1944 Please see website below for full comment. Canals Strategy (CP53).

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011

Core Strategy section 6.5 SO5: to protect and enhance the natural environment We are disappointed that there is no mention in the Core Strategy document of Biss Meadows Country Park or similar urban fringe country parks in respect of the natural environment and bio-diversity. We believe that when country parks are suitably developed to support and enhance wildlife, they make a positive contribution to both urban life and to the natural environment and bio-diversity by: - bringing more wildlife into the adjacent urban housing and employment zones, thus making them less sterile and more enjoyable places to live and work - providing urban citizens with a more intimate connection with the natural world. The importance of country parks is acknowledged and This in turn leads to more appreciation of ecology and the natural environment and greener living - being has been referenced in the GI policy, and indeed country very accessible to large numbers or urban citizens, especially without the need to use transport - 1996 parks are proposed for each of the main housing Green spaces providing a place to relax thus enhancing physical and mental well being - providing a refuge for wildlife allocations. Further details on country parks are likely to between the intensive farmland and the build environment. This protects and enhances the natural be developed through the GI strategy. environment and bio-diversity. - reducing the pressure on the more sensitive wildlife sites elsewhere in Wiltshire In particular an extended Biss Meadows provides a strategic natural link between Biss Wood, Green Lane Wood and the Town Park. We note that the supporting Draft topic paper 13: Green infrastructure mentions the “ opportunities for enhancements/ improvements at four country parks in west Wiltshire ” including Biss Meadows, but there is a key omission not to include these country parks within the main Core Strategy document. In fact there is not a single inclusion in the Core Strategy of the words: country park . Cross No. Comments Officer Comments Issue Reference 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 the Wilts & Berks canal in the strategy. This is a significant omission that ignores the positive impact that the restoration of both these canals will have in economic A specific canal policy has been added to the Core 2074 terms as well as the beneficial environmental and social outputs that the restorations will deliver. The Canals Strategy (CP53). economic benefits of restored canals are well documented; the Kennet & Avon canal for example 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 Core Policy 33: Biodiversity and geodiversity The second paragraph of CP33 should be reworded to " development proposals affecting local sites must fairly and reasonably contribute to their favourable management in the long-term ". In accordance with Planning Policy Statement 9: Biodiversity and Geological Conservation (August 2005) it is not unreasonable for development that has an effect on a local site to contribute to its favourable management. However, the contribution must be proportionate to The requirements of Circular 05/2005 are acknowledged the impact and, if secured through a planning obligation / agreement, it must meet the tests of Circular and have been considered in revising this policy. 05/2005 as amended by the CIL Regulations 2010, i.e. it must be: (d) "necessary to make the Wording in relation to biodiversity gains is already as development acceptable in planning terms (e) directly related to the development; and (f) fairly and suggested. Mitigation for recreational disturbance on reasonably related in scale and kind to the development." PPS9 identifies that planning decisions " SPAs has been agreed through discussions with Natural should aim to maintain, and enhance, restore or add to biodiversity of geological conservation interest" England. Offsite impacts generally require an offsite (emphasis added). The third paragraph of CP29 should therefore be reworded to "major development in Biodiversity solution, with the possible exception of SANGS, which particular will include measures to deliver biodiversity gains...." The second half of CP33 identifies what loss / Special 2105 have been offered as an option, although this is more will be included as suitable mitigation measures in order to offset impacts on the Salisbury Plain Special landscape expensive for the developer and less likely to be effective Protection Area (SPA) and New Forest SPA. As the list of mitigation measures is not necessarily areas and therefore not a preferred option. Support for former exhaustive, the word "will" should be changed to "could". CP33 should also acknowledge that where CP34 noted. SLAs will be reviewed as part of a mitigation measures can be achieved within an application site boundary, they do not need to be landscape strategy, which is likely to be an SPD and secured through a planning obligation and could form part of the wider development proposals from the therefore subject to public consultation. Local plan outset. Core Policy 34: Landscape We generally welcome CP34 and the council's decision to move from policies on SLAs will be saved until such time as the SPD local landscape designations (such as Special Landscape Areas LCAs) to Landscape Character is adopted. Assessments (LCAs) that are supported by criteria based policies. Paragraph 6.5.15 explains that the SLA network will be reviewed to identify any areas with unique characteristics that would not be adequately protected by a criteria-based approach. It is unclear when this review will be undertaken and whether SLAs will remain a material consideration in the decision making process until this review is complete. It is also unclear whether this review will be subject to public consultation. Cross No. Comments Officer Comments Issue Reference Strategic Objective 5: to protect and enhance the natural environment Section 3.8 We consider this objective should be widened to include the protection and improvement of the water environment, as required by the Water Framework Directive . Alternatively a separate strategic objective could be included to cover the water environment. In particular the Core Strategy should include key outcomes to protect and improve the quality and quantity of water within streams, rivers, wetlands, as well as groundwater. Currently there is a key outcome relating to water abstraction, but protection and improvement of the quantity/ flow of water resources is more than purely abstraction issues. Also water quality, and other factors affecting the natural water environment should be considered. The SA and Core Strategy policy should refer to the actions given in the River Basin Management Plans that fall within Wiltshire which were produced under the Water Framework Directive (WFD). This strategic objective should also include reference to protecting and if possible improving groundwater , which is an Water important resource in Wiltshire. As part of this the Core Strategy would need to take into account our 2151 SO10 WFD commitments have been addressed through CP68 abstraction / ‘Groundwater Protection Policy and Practice' (GP3), which includes our aims and objectives for WFD groundwater, including the types of development that would or would not be appropriate in particular Source Protection Zones and aquifers. Significant areas of Wiltshire overly principal aquifer (classification that replaced Major Aquifer). There are a number of important groundwater abstraction in Wiltshire which are used to provide public water supplies. It is vital that these abstraction are protected. In order to protect the public water supply abstraction the Environment Agency has designated Source Protection Zone, around the abstractions. The importance of these groundwater resources may well increase if climate change puts more strain on water resources. Further information regarding our policies and advice in relation to Groundwater can be found in our publication "GP3 (Protection: Policy and Practice)" (please note that this replaced our "Policy and Practice for the Protection of Groundwater" publication) Groundwater could also be impacted from historic uses of land that could cause ground contamination. This should be addressed within the Core Strategy. Core Policy 33: Biodiversity and Geodiversity We support this policy. Core Policy 34 - no comments. River corridors / country parks are included in sub- Core Policy 35: Green Infrastructure We presume that river corridors/country parks are included within 2173 regional green corridors - this will be clarified through the the sub-regional green corridors. If so, we recommend this is clarified in the policy. Core Policy 36: GI strategy. Green Infrastructure development management policy We support this policy.

The ongoing development of the Cotswold Water Park (CWP) will remain of shared interest between Wiltshire Council, Cotswold District Council and GCC. I note that reference is made to the CWP in the section on Green Infrastructure. However, it fulfils a wider role within the area in terms of minerals extraction, tourism, recreation, heavy goods vehicle (HGV) movements etc. It is a large area that raises a number of complex land use planning issues that need cross boundary cooperation. The CWP and the Specific policy on CWP added to address these specific need for cross boundary working should be given greater prominence within the emerging core strategy. issues and bring it in line with emerging CDC policy. Cotswold 2253 We welcome the Core Policy 33 on Biodiversity and Geodiversity. However, I note that the policy does Sites protected by national / international legislation do Water Park not refer to Sites of Special Scientific Interest, PPS9 paragraph 8 specifically states these sites should not require policy protection, however these other be given a high degree of protection through the planning system through appropriate policies in plans. mechanisms will be highlighted in the supporting text. Although international sites do not require a protection policy in (PPS 9 paragraph 6) it may also be helpful to include additional information on those present and how they are protected through European Directives. Some explanatory text within this core policy will allow for cross referencing from the relevant Community Area Strategies (CAS) and the HRA. Cross No. Comments Officer Comments Issue Reference

Comment No 2299 by M G Rodd (ID. 550599)

A specific canal policy has been added to the Core 2299 Please see website below for full comment. Canals Strategy (CP53).

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011

Policy CP34 Agree that Landscape Plans play an important role in understanding the distinctiveness of an area. These plans not only ensure the extent of the landscape area and what needs to be protected is fully understood, but importantly enables the design of the proposed development to respond to the special character of the landscape of the area. Policy CP35 Green Infrastructure plays an important role in ensuring that development proposals on previously undeveloped sites provide a sufficient links to 2342 Support for these policies noted. connect the site with existing green spaces and provide linear spaces, which assist in leisure and recreation opportunities as well as facilitate the safe movement of wildlife through the development. Policy CP36 In order to mitigate the impact of a proposed development, particularly on previously undeveloped site it is important to understand its potential impact on the existing green infrastructure, agree that major developments should be supported by a Green Infrastructure Audit.

I am concerned that the above policy contains no clear pledge to protect the Historic Route of the Wilts & Berks Canal or for the proposed new link at Melksham. As protection was originally included by the old A specific canal policy has been added to the Core 2355 Canals North Wilts DC and West Wilts DC I find this confusing, and especially so as Wiltshire Council is a Strategy (CP53). member of the Wilts & Berks Canal Partnership.

Policy 35 Para 6.5.20 National planning policy and other relevant references PPS5 English Heritage comment The role of GI in enhancing both the natural and historic environment should be The historic landscapes of Wiltshire will be an important acknowledged. For example the canal network and historic landscape are important heritage assets in element of its GI, but this must be planned in a 2450 Wiltshire affected by any GI strategy enabling for e.g., improved presentation, access and enjoyment. Canals sustainable manner to avoid damage / infrastructure Archaeology is particularly relevant in relation to GI planning. English Heritage recommended change problems - this will be set out in the GI strategy. Ensure Policy 35 and 36 highlight the contribution of GI to the delivery of a positive and proactive conservation strategy for the HE in Wiltshire - see below.

STRATEGIC OBJECTIVE 5 There should be a greater emphasis on the commitment of the Wiltshire Protected species / sites do not require policy protection 2612 Council for the protection of designated areas and protect species, especially those which are protected and indeed this would duplicate national legislation / by European law. policy. Cross No. Comments Officer Comments Issue Reference 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 While the suggested wording is longer, this repeats that an alternative scheme or location is sought. Suitable mitigation measures will include: i. Securing standard procedure for appropriate assessment (Reg.61) management measures for Stone Curlew on Salisbury Plain and surrounding areas. ii. habitat and does not add anything to the policy. CP51 should enhancement for Night jar, Wood lark or Dartford Warbler within the New Forest National Park; iii. not repeat reference to AONBs in the draft NPPF. provision of an appropriate area of Suitable Alternative Natural Greenspace to deter public use of Nature National policy and the ELC requires a movement away 2000 sites; and iv. securing access management measures on Salisbury Plain and in the New Forest. Biodiversity from deliniating landscape areas with the exception of Such measures shall be secured through planning obligations and agreements which will be drawn up loss / AONBs / AONBs and a move towards criteria based policies such 2643 and approved by the appropriate bodies before permission is granted. All developments proposals shall Special as CP51. SLAs are subject to review based on incorporate appropriate measures to avoid and reduce disturbance of sensitive and protected wildlife landscape forthcoming evidence - local policies will be saved in the species throughout the lifetime of the development. " Core Policy 34 1 Para 6.5.12 This paragraph areas interim. Green spaces are an integral part of GI and needs to be reviewed in the light of the references to AONB's in the Draft National Planning Policy should be planned as a network. Local areas will have Framework. 2 Add to bullet point (iii) of the Policy, "through the delineation of highly valued landscapes" . the opportunity to identify and protect important areas of 3. It is not agreed that Special Landscape Areas should be scrapped. They play a valuable part of green space through the neighbourhood planning planning management. Paragraph 6.5.20 Green space needs to be dealt with separately from green process. 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 ..... "

The various District Plans had specific wording to protect the line of the Wilts & Berks Canal from future development. Ray Denyer and myself and spent considerable effort to achieve this when we were responsible as The Wilts & Berks Canal Local Authority Liaison Officers for the Wiltshire area. I particularly find it very disappointing to see so little mention of the canal in the new County Spatial A specific canal policy has been added to the Core 2672 Planning Policy that has just been brought to my attention. It is essential that the County Council Canals Strategy (CP53). recognise this canal protection policy in the wording of the County Spatial Planning Policy and I request that amendments are made in this document. As an additional comment, I was disappointed to see once again the canal referred to as "The Wiltshire and Berkshire Canal". It is well documented as to why its name is "The Wilts & Berks Canal".

Comment No 2674 by Kevin East (ID. 557536)

A specific canal policy has been added to the Core 2674 Please see website below for full comment. Canals Strategy (CP53).

http://consult.wiltshire.gov.uk/portal/spatial_planning/wcs/wcsconsult2011 Cross No. Comments Officer Comments Issue Reference

I write on behalf of the Batscapes: Making Connections Project to endorse the comments and documentation submitted byGareth Harris, Jenny Bennett and Dr. Fiona Matthews. I apologise for my delay in writing to you and hope you will still consider these comments. The Batscapes: Making Connections Projectis based in the West Wiltshire region andare we arecurrently in the process of Noted. Landscape scale projects will be supported where 2680 developing a project that will raise awareness of thevery highimportance of this area for bats.The Bats possible through CP50. Projectalsoendeavours to widen our existing knowledge of bats across the area and engage with local communities to participate in recording bats and protecting them in the future.The Project is supported by a wide range of partners, if you would like any further information please do not hesitate to contact me.

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 roosts is particularly important to ensure the long-term survival and viability of bat populations. Planning for bats therefore needs to be addressed at an integrated landscape scale to ensure bat populations can use and travel between a network of roosts All British bats and their roosts are fully protected under and foraging areas. A strategic plan-led approach to development is required to ensure key habitat the Habitats Regulations, and individual roosts and features for bats are protected and remain connected into the surrounding landscape. It should also be habitat features will be protected through that regime. noted that there is the potential for severe impacts to arise to the bat assemblage in Wiltshire due to the The Core Strategy is based on all of the available data 2683 impacts of lighting associated with development. As such, protection and enhancement of the Wiltshire Bats held by Wiltshire and Swindon Biological Records Centre. bat assemblage alongside new development cannot be achieved through provision of green If Wiltshire bat group have further information which is infrastructure alone - strategic planning for bats in Wiltshire requires at the minimum retention of relevant this should be shared with the BRC or directly important roosts, commuting routes and foraging areas within a network of dark corridors and zones. with Wiltshire Council to inform the planning process. The Draft Core Strategy and the Nature Conservation Topic Paper make little to no mention of the potential for severe negative impacts at a strategic level to an internationally-important nature conservation asset. As such, it is considered uncertain whether 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.

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 people living in the AONB. The Cotswolds 2729 Conservation Board having examined the document wishes to make the comments as detailed in the Noted. AONBs 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. Cross No. Comments Officer Comments Issue Reference

Whilst supportive of the policies for areas which include the Cotswold AONB, the Board woudl wish to see a consistency of approach applied to these strategies with respect to consideration of AONB's. For example, the Corsham Area Strategy includes reference to 'The outstanding value of thelandscape aroudn the Cotswold AONB will be protected and opportunties for Corsham to be promoted as a tourist Relevant CA policies have been revised to include 2731 BoA AONBs destination should be explore'. This statement could be applied to other areas, including Bradford on greater reference to AONBs Avon. Some area strategy maps, such as Map 5.8 for the Bradford on Avon Community Area, do not show the AONB. The criterial for acceptable development at Bradford on Avon should include an assessment of its impact on the Cotswold AONB.

CP 34 - the cotswold conservation board supports this policy in general. However it is suggested that Suggested wording does not make appear to make 2736 the opening sentence should read ‘development will be supported where it should protect s , conserves, gramatical sense. and where possible enhance s landscape character.

Para 6.5.10. The first sentence shoud read 'The important significance of the landscape of Wiltshire is 2737 acknowledged in the national designation of 44% of the area administered by Witlshrie Council as an Date of management plan to be changed. AONBs AONB. The Cotswold AONB Management Plan 2009-2014 is dated 2008-2013. 1. The county, being rural in nature, needs to recognise that one of the attractions to the current and future populations is the natural environment and natural history of the county. Climate change policies, agriculture and industry all impact on this aspect and the plan should have a specific section for this area to consider soil quality and landscape protection around WHS and similar historic building settings. Section 3.8 "Protection of the agricultural soil quality" will require a means of recognising the need to manage landscapes around WHS and other Scheduled Monument sites in order to secure stability in The WHS is protected through CP59. BMV soils are ground water levels as well as soil erosion prevention. Lowering of ground water has a major impact on protected under national policy. Water abstraction is Water 2747 archaeological preservation, particularly in sensitive areas such as Marden Henge or the Upper Kennet SO6 controlled by the EA through the licensing regime. abstraction Valley, including Silbury Hill and Avebury Henge. Whilst it is pleasing to see the statement that Important historic assets are recognised through listing, development will "incorporate measures to control risks to European Protected sites" the strategic plan conservation areas and recognition as SAMs. could be improved by identifying that an action is required to define and understand what is worth protecting that is not covered by the European directive. (The European designation only refers to the larger and well known WHS and similar.) Other landscapes and buildings can be just as compelling and the identification of these could be achieved by the co-ordination of the many community bodies and organisations within the county. WANHS could assist here. 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 opportunities exist in The Core Strategy now includes a specific policy on the Cotswold 2762 the CWP to deliver much of the spatial strategy but such opportunities are likely to be missed unless the CWP (CP53) Water Park Core Spatial Strategy incorporates the themes of the masterplan, South West Nature Map in the CWP, and the CWP Biodiversity Action Plan.

Core Policy 33 - Biodiversity and geodiversity With respect to the disturbance of key habitats, the Cotswold Water Park should also be included. The CWP supports a nationally and internationally CP50 requires all development proposals to avoid and important population of breeding and wintering waterbirds, of which many species are very prone to reduce disturbance upon sensitive wildlife species. A Cotswold 2770 disturbance. Since the CWP exceeds criteria for a SSSI for waterbirds, as well as for a Special specific policy on CWP addresses ecological impacts Water Park Protection Area (SPA) under the EU Birds Directive, thereby representing a nationally and internationally from recreation developments in the areas. important population, this population should be maintained, enhanced and protected from inappropriate developments. Special attention should be paid to balancing human recreation and sensitive species.

Core Policy 33 does not currently address the potential for severe negative impacts at a strategic level to Protected species and sites are protected under national nationally and internationally-important populations of key wildlife such as bats, waterbirds etc within Biodiversity 2771 legislation and policy. Local policies aim to protect all Wiltshire. It is recommended that Core Policy 33 is revised to include specific criteria aimed at reducing loss other biodiversity interests. impacts to populations to an acceptable minimum. Cross No. Comments Officer Comments Issue Reference

Policy 36; The policy wording should be caveated to determine that any Green Infrastructure to be retained should be both open and deliverable for actual public use. For instance, an existing area of green space, in private ownership and over which the public have no right of access should not be safeguarded by this policy but this is not clear from the supporting text, especially where in the past it Green infrastructure fulfils a much wider role than simply may have been considered (incorrectly) as a public open space. Moreover, it should not be counted amenity. Privately owned GI assets can make a positive 2807 towards any potential compensation measures either. The policy wording needs to specify that existing Green spaces contribution to the wider GI network and should be Green Infrastructure must be in use and/or available for public use/access to be considered as part of considered as an integral part of this network. the wider Green Infrastructure Network. Indeed, previous representations regarding the Core Strategy initial sites consultation (Reference number 230) have identified a potential development site currently constrained by the Kennet Local Plan - policy TR 17, but which is not public land. Its safeguarding serves no useful or valid planning purpose and such should not be implied by the Core Strategy

CORE POLICY 35 - GREEN INFRASTRUCTURE Crest and Redcliffe support this policy which seeks to utilise and build upon green infrastructure in the area. Core Policy 4 Chippenham Central Area of Opportunity identifies the opportunity presented by the River Avon corridor to improve it for recreational use including pedestrian and cycling linkages to the town centre. Indeed, as part of their proposals for a Southern expansion Crest and Redcliffe propose to improve the River Avon corridor into Chippenham town centre. This is the only option which can actively deliver this policy. (see Vision for South Chippenham) Accordingly it is considered that the River Avon corridor should be specifically identified Support noted. River corridors are included as sub- 2868 within the strategic network of green infrastructure where improvement is encouraged. Recommendation regional GI, however individual GI assets will be identified GI Identify the River Avon corridor as a strategic green infrastructure corridor. CORE POLICY 36 - GREEN through the GI strategy. INFRASTRUCTURE DEVELOPMENT MANGEMENT POLICY Crest and Redcliffe have no objections to this policy which seeks to ensure the long term management of Wiltshire Green Infrastructure network. As referred to in response to Core Policies 4, 5 and 35, Crest and Redcliffe propose improvements to the River Avon corridor to enhance its recreational and sporting uses as well as linkages to the town centre. These improvements would be accompanied with a Management Plan which would set out the long term management for the area

Question 21 - NE Comment No. 11 Comment No. 1109 Comment No. 1944 Councillor Julie Swabey Charles Routh Mr John Webb Planning and Local Government The Inland Waterways Association Member Wiltshire Council Natural England Avon and Wilts Branch Comment No. 115 Comment No. 1113 Comment No. 1996 David Feather Charles Routh Mr Alan Cooper Planning and Local Government Committee Member Friends of Comment No. 143 Natural England Biss Meadows Country Park Mr Andrew Lord Comment No. 1115 Comment No. 2074 Planning Advisor North Wessex Downs AONB Charles Routh Kim Chester Planning and Local Government Development Manager The Comment No. 147 Natural England Waterways Trust Mr Andrew Lord Comment No. 1159 Comment No. 2105 Planning Advisor North Wessex Downs AONB Kate Fieldon Mr Peter Lamb Vice-Chairman The Avebury Senior Planner Terence O'Rourke Comment No. 155 Society Ltd Mr Andrew Lord Comment No. 1174 Unknown Planning Advisor North Wessex Downs AONB Mora Abell Bloor Homes Ltd Comment No. 228 Comment No. 1185 Comment No. 2151 Mrs Charlotte Hitchmough Richard Coleman Miss Katherine Burt Planning Liaison Technical Specialist Environment Agency Comment No. 263 ARK (Wessex Area) Steve Riley Comment No. 1190 Comment No. 2173 Comment No. 293 David Stoyle Miss Katherine Burt Planning Liaison Technical Specialist Environment Agency N Nelder Comment No. 1299 (Wessex Area) Development Adviser Cotswold Canals Trust Martin Buckland Comment No. 2253 Comment No. 294 Comment No. 1463 Robert Niblett Planning Officer Gloucestershire N Nelder Richard Burden County Council Development Adviser Cotswold Canals Trust Comment No. 1477 Comment No. 2299 Comment No. 356 Tom Pepperall Dr M G Rodd Chair Kennet and Avon Canal Mr Robert Gillespie Lydiard Millicent Parish Council Trust Ltd Managing Director Environment Bank Ltd Comment No. 1478 Comment No. 2342 Comment No. 359 Tom Pepperall Mr Anthony Aitken Mr Robert Gillespie Lydiard Millicent Parish Council Colliers International Managing Director Environment Bank Ltd Comment No. 1514 Unknown Comment No. 458 Mollie Groom Mactaggart & Mickel NORTHERN COMMUNITY AREA ms lorna llewellyn PARTNERSHIP Comment No. 2355 Comment No. 477 Comment No. 1569 Mr Doug Small Mrs. Marylyn Timms Mr E East Comment No. 2450 Clerk Hilperton Parish Council The Trust For Devizes Rohan Torkildsen Comment No. 492 Comment No. 1583 English Heritage Mr Barry Dent Bradford on Avon Town Council Comment No. 2612 Town Clerk Bradford on Avon Chairman Malmesbury Civic Trust Town Council Mr George McDonic Chairman Campaign to Protect Comment No. 568 Comment No. 1617 Rural England - Wiltshire Branch Mr Ken Oliver Mike Lang Comment No. 2643 Canal Officer Wiltshire Council Comment No. 1631 Mr George McDonic Chairman Campaign to Protect Comment No. 618 David Chalmers Rural England - Wiltshire Branch Mr Justin Milward Comment No. 1661 Comment No. 2672 Regional & Local Government Officer QWoodland Trust Mr M Drennan Mr Vic Miller Comment No. 619 Planning Manager Sport England Wilts & Berks Canal Trust Mr Justin Milward Comment No. 1689 Comment No. 2674 Regional & Local Government Officer QWoodland Trust Charlotte Watkins Mr Kevin East Waterways and Environment Comment No. 662 LP Planning Manager Canoe England Mrs C Spickernell Mr & Mrs W Driver Comment No. 2680 Comment No. 683 Comment No. 1726 Unknown Mr Philip Sheldrake Phil Rice Batscapes Conservation Officer RSPB (South West) Malmesbury Town Council Zoe Pittaway Farming and Wildlife Advisory Comment No. 684 Comment No. 1732 Group Mr Philip Sheldrake Peter McHenry Comment No. 2683 Conservation Officer RSPB (South West) Comment No. 1733 Gareth Harris Comment No. 692 Mr John Gornall Wiltshire Bat Group The Inland Waterways Association Ms Helen Kent Avon and Wilts Branch Comment No. 2729 Associate Land Use Consultants Unknown Ms Carole Topple Chairman, Living and Working Sub Committee Cotswold Conservation The Burser The Inland Waterways Association Board Dauntsey's School Comment No. 1740 Comment No. 2731 Comment No. 703 K Pidgeon Ms Carole Topple Chairman, Living and Working Sub Committee Cotswold Conservation Brian Roberts Comment No. 1795 Board Comment No. 730 Mr Kevin Burnside Comment No. 2736 Mr Bleddyn Griffith Friends of Woolley Ms Carole Topple Chairman, Living and Working Sub Committee Cotswold Conservation Comment No. 757 Comment No. 1817 Board Mr Tony Sedgwick S Dempster Comment No. 2737 Traffic Advisor Trust for Devizes ARK Ms Carole Topple Chairman, Living and Working Sub Committee Cotswold Conservation Comment No. 788 Comment No. 1884 Board Dr Chris Gillham Mr D Rowden Comment No. 2747 Comment No. 952 Comment No. 1894 Ms Karen Jones Marketing & Administration Manager Wiltshire Archaeology Mr Tony Peacock Ms Anna Forbes and Natural History Society Coordinator The Showell Protection Group Action for the River Kennet Comment No. 2762 Comment No. 953 Comment No. 1898 Gareth Harris Mrs Jenny Stratton Mrs M S Carey Cotswold Water Park Trust Comment No. 1038 Box Parish Council Comment No. 2770 Ms Jenny Hawley Comment No. 1900 Gareth Harris Environmental Intelligence Officer Wiltshire Wildlife Trust Mr David Illsley Cotswold Water Park Trust Policy Manager New Forest Comment No. 1067 National Park Authority Comment No. 2771 Sally Hoddinott Comment No. 1923 Gareth Harris Clerk Potterne Parish Council Mr David Illsley Cotswold Water Park Trust Policy Manager New Forest Comment No. 1073 National Park Authority Comment No. 2807 Charles Routh Comment No. 1926 Mr S Chambers Planning and Local Government Natural England Mr Patrick Kinnersly LPC (Trull) Ltd Comment No. 2868 Unknown Crest Strategic Projects Limited & Redcliffe Homes Ltd D2 Planning Limited