Sent: 04 March 2016 11:41 To: Staincliffe, Mark; Pearson, Mathew Subject: Rawlings Farm and East of Chippenham This email is sent on behalf of the Tytherton Lucas Residents Association. It is sent to OPPOSE the following applications: Planning Application 15/12363/OUT Chippenham Riverside. Objection. Mathew Pearson Planning Application15/12351/OUT. Rawlings Green. Objection. Mark Staincliffe 1. Premature This opportunistic application has been presented to bypass the inspectors hearing later this year. The developers hope that by applying for planning permission now they will be able to avoid having to justify their evidence to the inspector. This application should be rejected and the decision should be left to the inspector when he has received a new list of appropriate sites from the council together with the new evidence that he has requested. In the light of the views expressed by the inspector it would appear that the sites at Rawlings Green and East of Chippenham should be treated as unsound and should not be considered prior to his decision later this year. Given the fact that there is no adopted or emerging sound policy that can justify these two proposals, limited weight should be given to the CSAP until the inspector makes his decision. Each site must be treated seperately with no assumption that the other site will be built. 2. The case for the ELR has not been adequately justified The evidence provided to the inspector relied on out of date evidence and heavily biased scenarios. It also failed to consider a SLR which would link with the A350 which is the key road identified by the council as the economic artery of Wiltshire. The council was asked to obtain new evidence. The inspector also stated that he wished to retain, at the council's cost, his own traffic expert. The Inspector was concerned that it would affectively act as a bypass and encourage out- commuting which is contrary to the adopted core strategy. The council has not included in its policy a need for either an ELR or a SLR. The case for the ELR, according to the developers, is that it will reduce traffic in the town centre. In which case it raises the legal question, which the inspector raised, of how can CIL payments be used to fund improvements not in the site the subject of the application. 3. Is the ELR deliverable? This depends on Rawlings farm developers building the ELR to the boundary of the East of Chippenham site, Which requires a bridge over the railway. Then it requires C2020 to continue the road down to Abbeyfields School having built a bridge over the Avon for the road and a bridge for the cycle track. As the inspector said it only needed one link in the chain to break and the whole road was not capable of delivery. There is no guarantee that the developers will continue building after the minimum amount required as the next additional house would cost millions and millions of pounds. This also appears that the link road has a different purpose between the different sites. In the case of Rawlings farm it goes through the houses whereas in the case of east of Chippenham it is the outer boundary. Will the residents of Rawlings green want a bypass running through their houses? The proposal is not a sustainable development since it fails to address the phasing and delivery of the other developers (it needs East of Chippenham, Rawlings Green and North Chippenham Consortium), especially the link road therein, which is necessary for the development to avoid an unacceptable impact on surrounding road junctions and traffic movements across Chippenham as a whole. Such impact would be contrary to CP3, CP10, CP61 and CP62 of the Wiltshire Core Strategy 2015. Finally it is not clear from the plans that the end of the road in the Rawlings Green development joins the road at the beginning of the East of Chippenham development. As the plans are final in respect of transport if they do not join then both schemes fail. 4. Number of houses The inspector was concerned at the number of houses proposed. These 2 sites alone provide 2200 homes. To this must be added any brownfield sites and probably the Crest/ Redcliffe site of 1000 homes as this was the council's first choice. This would result in nearly 4000 houses being built while Chippenham needs to provide 1935. A massive over supply. C2020 wish in due course to build upto 2600 homes on their site. As c2020 wish to apply for almost twice as many houses as listed in the CSAP, this casts doubt on the soundness of the CSAP as a whole. 5. Landscape We have obtained an independent landscape report from WHLandscape Consultancy Ltd which has already been forwarded to you. This report should be given at least equal weight to the report obtained by the developers. Our instructions to the author were not to give us the report we wanted, but to look at it independently and provide his own views. He has made it clear that no development should extend north of the cycle route. We strongly dispute the evidence provided by C2020 that there will be no noise or light pollution. Also that our views are in effect not disturbed. A letter signed by over the residents has been sent to the council objecting to those statements and making it clear that they object to this proposal. The proposal would have an unacceptable impact upon the tranquil nature of this part of the countryside, from the setting of listed buildings at Tytherton Lucas as well as its relationship to the nearby village of Tytherton Lucas. This proposal is therefore contrary to the provisions of CP 10, CP 51, CP 52 and CP 58 of the Wiltshire Core Strategy 2015, the NPPF as well as section 16(2) and 72(1) of the Planning (Listed Building and Conservation Area) Act 1990. 6. Air pollution No tests were carried out in Calne where the NOX levels exceed EU levels. The ELR would exacerbate the levels. We understand the council will be looking at this. 7. Connection to J17 of M4 We understand the council gave its reasons as to why it would have rejected the additional houses at Barrow Farm if an application had been made on the basis of Highways England view that no new houses should be built until the junction had been sorted. If a development for 500 homes was rejected on that basis certainly applications for 2200 homes should be rejected. The application fails to set out a scheme that would ensure the delivery, at the appropriate time, of the necessary improvements to J 17 of the M4 so as to render the strategic road network safe. As such, the application would not meet the requirements of CP10, CP62 and CP66 of the the Wiltshire Core Strategy 2015. 8. Self containment of Chippenham Out commuters will be attracted to live near to the ELR with access to the M4 and railway station. This is contrary to the core strategy. The proposal fails to provide a suitable bus strategy so as to demonstrate sustainable connections to Chippenham town, thereby failing to meet fully requirements of policy CP61 of the Wiltshire Core Strategy 2015. 9. Flooding The assumptions about mitigation of run-off are unrealistic. This is particularly important in the light of revisions to flood risk assessment assumptions currently being undertaken by the environment agency. As development is up stream of Chippenham any error could result in Chippenham being flooded. 29/12/15. David Rooke, deputy chief exec of EA told BBC: "we are moving from known extremes to unknown extremes. We will need to have a complete rethink." We need to let the EA re-assess its models as otherwise we could find the SuDs were insufficient. Current EA advise may be updated later this year and thus prove not to be robust. Raising the banks of the Avon as suggested by C2020 could cause huge damage upstream and flood farm land in Tytherton Lucas. This must not be allowed to occur. 10. Bremhill and Calne The site east of Chippenham is mainly in the parish of Bremhill. Bremhill in the neighbourhood plan have made it clear that they do not wish to have any substantial development. Their views should be followed. In addition as the development is in Calne CP8 applies, and the number of houses required under CP8 have been exceeded. At present, there is no Chippenham Site Allocations Plan (CSAP) adopted within the Wiltshire Core Strategy. Therefore this application site lies outside of the limits of development for Chippenham, as defined by Policy CP1 and CP10 of the Wiltshire Core Strategy. While the CSAP DPD can provide input into the application, surely the application has to be judged against only adopted policies and spatial strategies. Therefore this application should be considered within the only existing policy and Spatial Strategy for this development land, Core Policy 8 Spatial Strategy: Calne Community Area. 1) Plan CP8 calls for 165 homes in the area outside Calne itself. This application is for some 1500 homes, far in excess of the number required in the plan period. 2) This application is not “protecting and enhancing the important ecological value and landscape character of the River Marden corridor” as stipulated in bullet 3 of paragraph 5.41 of the Issues and Considerations of CP8. 3) The application does not identify “an appropriate solution to reducing impact on traffic from the waste facilities located on the edge of Calne” as stipulated in bullet 4 of paragraph 5.41 of the Issues and Considerations of CP8.