22 Grange Lane Warminster Wiltshire BA12 9EY 9th December 2016 Dear Sir Based on my experience as a member of the Warminster Neighbourhood Planning Working Group I am very concerned by the proposed planning application reference 16/10502/OUT and would like to register my objections. Development Principles (Wiltshire Core Strategy CP1) The underlying principles of the Wiltshire Core Strategy seek to manage future development to ensure that communities have an appropriate balance of jobs, services and facilities and homes. The strategy recognises that previous growth hasn’t always been delivered in a proportionate manner whereby housing is delivered in settlements where there are insufficient employment opportunities leading to out-commuting. This is the reason why the West Urban Extension is a mix of housing, employment land, primary school, local amenities etc. This development is purely a housing development and does not meet the principles of the Core Strategy in providing balanced facilities that are needed for a self-contained community. The development does not provide additional employment area and so for new local employment relies on the employment area being developed to support the needs of the West Urban Extension. Wiltshire Council and Warminster Town Council have both recognised that Warminster is unusual in that more people commute out of town for work. The main towns for work near Warminster are Bath, Westbury, Trowbridge and Salisbury. With the exception of Salisbury all of these would involve households from this site crossing Warminster Town Centre. It therefore will contribute to Warminster’s current traffic problems relating to commuting through the town centre and Copheap in order to reach the new employment area on the West Urban Extension or go towards Bath, Frome, Trowbridge and Westbury. Settlement Boundary (Wiltshire Core Strategy CP2) Core Policy 2 states that within the limits of development, as defined on the policies map (which have been carried across from the H1 Town Policy Limit boundary line of the former West Wiltshire District Plan 1st Alteration 2004), there is a presumption in favour of sustainable development within the market towns. However, outside the defined limits of development save for the exceptional circumstances detailed within paragraph 4.25 of the development plan (such as affordable housing), development will not be permitted. The site is outside of the defined limits of development for Warminster and would therefore be considered to be contrary to CP2 of the development plan. I am aware that Settlement Boundaries are currently being reviewed by Wiltshire but would point out that Wiltshire has twice asked Warminster Town Council for its views on a draft boundary. At both of these meetings the Council decided not to recommend including this site within the settlement boundary. In addition the Town Council formed a working group of residents tasked to produce a Neighbourhood Plan and steer it through consultation, examination and finally to be passed at referendum. Wiltshire Council have taken the decision pursuant to Section 38A(4) of the Planning & Compulsory Purchase Act, 2004, to ‘make’ the Warminster Neighbourhood Plan. This means that the Warminster Neighbourhood Plan now forms part of the Wiltshire Council Development Plan and the policies in the Neighbourhood Plan will be given full weight when assessing planning applications which affect land in the Warminster Neighbourhood Area. During the production of this Neighbourhood Plan the steering group in response to the draft plan consultation could have included this site within the settlement boundary but did not. 5 Year Housing Supply As indicated in the Planning Statement, Wiltshire is unable to demonstrate a 5 Year Housing Supply for the North and West HMA. The latest Wiltshire Housing Land Supply Statement calculation gives the housing supply as of 1st April 2016 as 5.13 years which is less than 5 year plus 5 percent requirement. It should be noted that the difference between these figures represents a shortfall of 161 houses. As a result of this lack of supply the supplied Planning Statement indicates that paragraph 49 of the NPPF, the housing policies of the adopted development plan cannot be considered up to date. The implication is that paragraph 14 is engaged and the application should be considered in the context of the presumption in favour of sustainable development. The question then becomes the weight that should be given to the planning policies. The recent Court of Appeal decision indicates that weight is not dictated by government policies in the NPPF but will vary according to the circumstances. Examples, given by the Court of Appeal, of circumstances that would affect the weight given in this judgment are The extent to which the policies fall short in providing for the five year supply The action being taken by the local authority to address it The particular purpose of a restrictive policy – such as protection of a green wedge As has already been stated Wiltshire’s latest calculation was 5.13 years but this was the situation as of 1st April 2016. In table 3 of the Housing Land Supply Statement document the number of additional sites identified beyond the monitoring base date of 1 April 2016 for the North and West HMA is over 3000. A significant number of these sites would count towards the 5 year supply meaning that at of 1st November 2016 Wiltshire has certainly has reached the 5.25 year target. I believe that the planning policies should be accorded full weight. Alistair Cunningham, Associate Director Economy and Planning, in Wiltshire’s recent Councillors Briefing Note 311 supports this belief and has stated - The Council would seek to defend its position and will also bring to the attention of the inspector those large sites that have been granted planning permission since 1 April. Housing Need Wiltshire's documentation now indicates that Warminster is 468 houses short of its target. The underlying reason for this shortfall has been the necessary delay in designing solutions for the problems associated the West Urban Extension development. Problems particularly associated with Warminster include secondary education places, flooding, pollution of the River Wylye, traffic, recreation, green buffer. Faced with these problems it was correct for Wiltshire to directly involve the people of Warminster, especially those most directly affected in the West, in the discussions as to how to develop the West Urban Extension. Time is required to provide the additional facilities needed to support development in Warminster and therefore the proposed rate of development on the West Urban Extension is the maximum possible given these constraints. The Hallam site does not provide any additional facilities and so rather than increase the overall number of houses completed it would limit the number that could be immediately developed on the West Urban Extension. River Wylye I was recently invited by Wiltshire Council to attend 'Our Community Matters' event. One of the items that was discussed at this event was the pollution problems associated with the River Wylye. Recognising that the River Wylye is a SAC, and as such is afforded the highest protection under law, I am extremely concerned by the comments from Wiltshire Council’s ecology officer (See Below). These comments indicate that if this development in conjunction with the West Urban Extension proceed there will be significant amounts of polution discharged in the river. Given that the West Urban Extension is the site selected in the Core Stragety for Warminster it would not be appropriate to hinder development by also granting permission for this application. Wiltshire Council’s ecology officer- “River Avon SAC - The development would presumably discharge to Warminster sewage works. This STW discharges into the River Wylye which is part of the River Avon SAC, a European protected site which has nationally agreed targets for its water quality. The targets are being widely breached across the catchment for phosphorus and the Environment Agency and Natural England have therefore published a Nutrient Management Plan to demonstrate how water quality will be improved over the next few years to ensure the targets are met. However, it is currently recognised there is a high risk that the plan will not deliver its objectives for the upper Wylye (and lower Avon) sub-catchments. The Council is therefore not able to approve planning applications that would discharge to Warminster STW where they would take the quantum of development above that forecast in the Wiltshire Core Strategy. Permitted and pending applications currently exceed the Core Strategy allocation and this places uncertainty in the short to medium term for further residential housing applications in the Warminster catchment. The Council is working with Wessex Water, the EA and NE to undertake further modelling of housing growth scenarios and identify the scope for measures that would offset additional forecast phosphate. This situation will have implications for the current pre-application site. Optimistically the matter could be resolved within the next year. However it seems more likely that significant further growth at Warminster may be delayed until after 2020 when advanced phosphate stripping technologies may be available for the STW. Flooding The site is subject to ground water flooding issues and a large part of the site is subject to surface water flooding issues. As a resident of Grange Lane instances of flooding have been reported to Wiltshire Council over the past few years. The site is within flood zone 1 in relation to fluvial flood risk. I have been studying the recent review of ‘The Winter Floods of 2015/2016 in the UK’ which brings together both river flow and meteorological data in an analysis of the events that led to extensive river flooding. This report considered the three months of ‘remarkably persistent and exceptionally mild cyclonic’ activity which, along with Storm Desmond, included the major storms of Abigail, Frank and Gertrude.