Local Plan Consultation - The Trust's response

Posted by Philippa Morgan on 10 March 2021

WILTSHIRE LOCAL PLAN REVIEW: CONSULTATION, Jan 2021
Representations by the Trust for Devizes

1. Emerging Spatial Strategy

1.1.The ‘Standard Method’ of projecting housing needs appears to be aimed at building
more extra houses than are likely to be required by 2036, in conflict with the stated
aim of the Plan (§2.1 of the Emerging Strategy document and the adjacent box on
the Climate Emergency). It also appears to conflict with the statutory requirement
in s39 of the Planning & Compulsory Purchase Act 2004, to pursue the objective of
contributing to the achievement of sustainable development. It is not sustainable to
plan for more housing than is needed, following the ONS/MHCLG household
projections, and we are not aware of any evidence that such a strategy would
contribute to the objective, in the context of Wiltshire. The ‘local needs’ projection
option is even more unsustainable.

1.2.Both options will lead to the following conflicts with sustainable development
patterns:
(i) Unnecessary growth in commuting to larger employment centres outside the
county, and consequently unnecessary growth in peak-hour traffic, contrary to the
objective to make the county zero-carbon.
(ii) Unnecessary development of undeveloped ‘greenfield’ land, and consequent
loss of land and soil resources.
(iii) An amplified feedback effect on future housing and other social needs, as
households attracted to the magnified housing supply generate more children, who
will in turn require education, jobs and additional housing a generation later.

1.3.The Trust considers the overall housing requirement at Devizes, and the residual
requirement, proposed on p14 of the Emerging Strategy document, to be about
right. However, over-provision elsewhere in HMA is likely to have adverse effects
on Devizes, chiefly through unnecessary additional peak-time traffic (residents of
Trowbridge and Melksham commuting to jobs in Swindon), and excess demands
for housing and social facilities.

1.4.However, the main threat of over-provision of housing numbers is that it will be
impossible in practice for the Council to maintain a credible 5-year supply of
deliverable housing land in the HMA or the county. This is likely to lead to
unplanned permissions for large-scale housing elsewhere in the HMA or the county,
irrespective of the spatial strategy and the Neighbourhood Plan. The main effect of
this level of threat and uncertainty is likely to be felt in large-scale, unplanned
housing developments at the market towns, such as Devizes, and in rural areas.
The Council should consider adding a policy mechanism, whereby the ‘double
presumption’ applied first to the town at which the land supply shortfall has arisen,
and then to the HMA where it has arisen.

1.5.The Plan should focus on ensuring that a sufficient number and range of homes
can be provided to meet the needs of present and future generations (NPPF §8(b)),

and that sufficient land of the right types is available in the right places and at the
right time to support growth (ibid (a)). We appreciate that the intention of the
standard method of assessment is to boost housing supply in areas of poor
affordability, but we fail to see how that can be expected to improve affordability
conditions without a major boost to the supply of entry-level housing. It does not
appear that the size, type and tenure of housing needed for different groups in the
community has been assessed, and these parameters are not reflected in the
emerging strategy (NPPF §61). Without this crucial component, we fail to see how
the strategy can be expected to have any beneficial effect on broad housing
affordability. Instead, it is likely to lead to indiscriminate and unsustainable
development, in conflict with the aims of the strategy.

2. Priorities

2.1.The Trust believes three priorities will be crucial to the future quality and liveability
of Devizes, and they are likely to apply to a greater or lesser extent to all the towns
and villages in the county: the landscape and ecological setting of the town; the
conservation of the historic fabric; and the design and quality of new development.
(a) Landscape & Ecological Setting

2.2.The Plan should give very high priority to the conservation and enhancement of the
natural beauty of the North Wessex Down AONB. High priority should also be given
to protecting the intrinsic character and beauty of the countryside generally, and
conserving the wider benefits from natural capital and ecosystem services –
including the economic and other benefits of the best and most versatile agricultural
land, and of trees and woodland (NPPF §170(b)). These are all important features
and assets of Devizes’ immediate setting, but insufficient weight is given to them in
Appendix 2 ‘Planning for Devizes’, and in the site assessments. In particular,
insufficient weight is given to conservation and enhancement of the AONB in the
assessments of sites 1 (adjoining Lay Wood) and 2 (Coate Bridge).

2.3.Our perception is that the town’s setting is a hanging valley, defined by a few
substantial topographical features, which should form the basis of planning policies
to conserve and enhance the natural environment in and around the town. See the
attached figures 1-3. Fig 1 shows the key topographical features overlayed onto
the Site Options. Fig 2 shows a ‘hillshade’ map, annotated with the features. Fig 3
shows an aerial photo, with the features annotated. These features are:
• the chalk scarp and toe slopes of Roundway Hill to the N and Etchilhampton Hill
(including the lower chalk hill at Gipsy Patch) to the E. These features are
included in the AONB. Site options 1, 2, 3 and 8 intrude into these features.
• the greensand scarp to the S (including Drews Pond woods and Furze Hill Lane);
the Old Park valley to the SW (crucial to the setting of the Castle); the scarp from
Caen Hill to Dunkirk Hill to the W (including the setting of the flight of locks); and
all the woodland features (including Belvedere Wood and Newlands Wood) along
the scarp between Dunkirk Hill and Conscience Lane (including Roundway Park)
to the NW, which connects to the chalk scarp at Roundway Hill. Site option 7 is
very intrusive into this feaure, from top to bottom of the scarp.

2.4.Many of the individual features identified above appear in Figs 2 and 3 of the
Appendix 2 Devizes pages. However, most of them appear as disjointed incidents,
and the underlying topography is ignored. Similarly, the Priority Habitats identified
in Fig 3 and the GI Corridors appear unrelated to the topography, which is the key
structure underpinning the habitats, watercourses, landscape and development
thresholds. We strongly recommend that the topography of towns should be a
conscious determinant in assessing proposals for landscape, biodiversity and
development/growth. This observation must be true of several Wiltshire towns: we
are thinking of Salisbury, Marlborough and Bradford on Avon.
(b) The Historic Town

2.5.Another key priority is finding a response to the effects of COVID and the internet
on Wiltshire’s town centres. The Trust expects big changes to the pattern of
activities in the historic town of Devizes, and in its town centre, in the near future.
However, we are uncertain of the nature and extent of the changes. This is
primarily because of COVID, but the govt’s announcement of sweeping, but as yet
unspecified, changes to the Use Classes Order, leave us, and presumably the
Council, in virtual vacuum.

2.6.Acknowledging the state of uncertainty, we believe the Local Plan should re-
emphasize the objective to promote the long-term vitality and viability of Wiltshire’s

town centres, and aim to maintain a strategic hierarchy. Assuming the govt will
move towards loosening controls, we believe there is an option to focus on the role
of Devizes as a mixed-use centre for business activity generally, as well as a retail
(class A) centre.

2.7.The crucial catalysts here will be the long-planned renewal of the Wharf area, and
the restoration of the Assize Courts, which we expect to add substantial boosts to
the vitality of the town.

2.8.Turning to the conservation of the historic fabric, our understanding is that
developments in Conservation Areas (CAs) and works to listed buildings (LBs) are
governed by the statutory objectives in the Planning (Listed Buildings &
Conservation Areas) Act 1990, rather than by s38(6) of the Planning & Compulsory
Purchase Act 2004 (the ‘plan led system’). Nevertheless, our view is that the
Council should have an explicit policy reflecting the special consideration it intends
to give to the desirability to conserve and enhance LBs and CAs, and the Core
Strategy is therefore right to include policy 58 (‘Ensuring the conservation of the
historic environment’). On a point of detail, we have doubts whether the
qualifications ‘where possible’ in the first para and ‘where appropriate’ in the second
are necessary, whether they properly reflect the statutory objectives, or whether
they provide unlawful excuses for ignoring opportunities to enhance CAs. In other
respects, we believe policy 58 should be retained.
(c) Quality & Design

2.9.The Trust’s perception is that the design quality of housing development, in
particular, has declined in the 2010s. The contrast in quality between phases 1 and
2 of the Quakers Road development in Devizes is especially glaring. The
Government is now emphatically committed to improving the design and quality of
new development; ‘we want to ensure that we have a system in place that enables

the creation of beautiful places that will stand the test of time’ (Pillar 2 of the
Planning White Paper, ‘Planning for the Future’).

2.10.Once again, Core Strategy policy 57 provides what should be a fairly robust, but
flexible framework for assessing the design quality of development projects. It
provides that projects should be ‘complementary to the locality’, and should
‘demonstrate how the proposal will make a positive contribution to the character of
Wiltshire’. It goes on to set out 14 more detailed criteria, from enhancing local
distinctiveness to the use of high standards of building materials. The NPPF now
provides support, saying that policies and decisions should ensure that
developments will ‘function well and add to the overall quality of the area’ (§127).
Our recent experience, however, is that the core policy has usually been ignored by
development managers and committees.

2.11.The 14 more detailed criteria in core policy 57 overlap a good deal with the 10
characteristics of good design identified in the govt’s recent National Design Guide.
Doubtless the Local Plan policy will be more robust if it is seen to align with govt
guidance.

3. Site Sifting

3.1.Our comments on the identified alternative housing development sites are as
follows. Most of these sites are on the edge of the town, and the key assessment
parameter is their impact on the open countryside, the AONB (in places), or the key
features of the town’s landscape and ecological setting, identified in §2.3 above.
Our main method for assessing that impact has therefore been to view the sites
from the open countryside, the AONB or the features of the setting, moving from the
open countryside in towards the option site.

Site 1 [SHELAA §662] Lay Wood. This site is very open to the N and the E,
where it abuts the AONB. The existing Lay Wood housing construction site to the
W appears to be separated from this site by an open space or landscape buffer,
presumably intended to mitigate the effects of the present development on the
AONB and open countryside to the E. The option site appears to form part of the
toe slope of the chalk hill to the N, rather than the greensand valley bottom to the S
and the E, and that may explain its very open appearance. Notwithstanding the
precise boundary of the AONB, this site appears to us to form part of the landscape
of the Vale of Pewsey, and therefore conceptually to belong as part of the AONB.
Laywood Bridge over the canal, on the S boundary of the site, is a listed building,
and there is a WW2 pillbox just to the N of the bridge. In our view, development of
this site would conflict with the statutory objective to conserve and enhance the
natural beauty of the AONB.

Site 2 [SHELAA §693] Coate Bridge which straddles the C class Coate Road,
would represent a substantial irruption into the open countryside between Devizes
and Coate. This is because the existing built-up area is largely hidden from view
from the Coate Road, whereas development here would be visible from some
distance beyond, due to the flat topography and the gappy character of the
hedgerows. The site abuts the AONB at its SE corner, but, as with Site 1, it appears
as part of the landscape of the Pewsey Vale, as regards character and continuity,
rather than the setting of Devizes. It should therefore be viewed as belonging

conceptually to the AONB. The site is relatively remote from sustainable transport
networks. A pedestrian/cycle crossing of the canal, and improvements to bus
services along Windsor Drive and London Road, and to cycling infrastructure along
the London Road corridor, would be the minimum needed to integrate the site into
transport networks. Development of this site would involve a disproportionately large
impact on the open countryside, relative to its size, and its housing yield. It would
also conflict with the objective to conserve and enhance the AONB.

Site 3 [SHELAA §624] E of Windsor Drive is perched on top of the low chalk hill at
Gipsy Patch, up to 35m higher than the general level of the built-up area of Devizes,
and would consequently appear elevated above the town. Development would be
easily visible from the N-S byway (the Wessex Ridgeway) which defines the AONB
about 400m (one field) to the E. The topography would represent a major
disincentive to walking and cycling from the town. Viewed in three dimensions, we
believe this site is a non-starter, because it conflicts with the form of the setting of
Devizes (see §2.2-2.3 above), with the AONB objectives, and with sustainable
transport objectives. We have given some thought to the S third of the site, S of the
E-W footpath, and on the S slope of the hill. But it would suffer from all of the
objections set out above, to a more limited extent, but provide proportionally smaller
housing yield.

Site 4 [SHELAA §524] Broadway Farm In contrast to Site 3, this site lies at the foot
of Etchilhampton Hill, on a level with the built-up area around Brickley Lane and
Nursteed Road. It is also not visible from the N-S byway (Wessex Ridgeway),
defining the AONB, cut off by the topography. It is visible from the summit of
Etchilhampton Hill, from where it appears in the context of the existing built-up area,
at the foot of the hillside. It is, however, very open, having no enclosure to the E,
except the lower slope of Etchilhampton Hill. It is also separated from existing
development by the N-S Sleight stream, which runs in a narrow wooded declivity
beside Windsor Drive. Development of this site would involve a major irruption into
open countryside, but its impact on the natural beauty of the AONB would be much
less than Sites 1, 2 and 3, and it fits much better into the topographical setting of
Devizes.

Site 5 [SHELAA §543] Marshall Road - Sleight Lane is also on a level with the
built-up area to the N, but the N third, between the A342 Andover Road and the low

embankment of the old railway lane give some containment to this part. The S two-
thirds is more open to the S and the W, and has no landscape containment in these

directions. Development of the N part would be a significant salient into the open
countryside, and would have a major urbanizing effect on the Andover Road gateway
into Devizes. However, the effect on the wider countryside would be contained to
some extent by the road and railway embankment. Development of the S part would
constitute a major urbanization of the S fringe of Devizes, with substantial effect on
the open countryside.

Site 6 [SHELAA §3259] Greenacres is very different in character, being an enclosed
landscape, formerly gardens within the grounds of the former Roundway Hospital. It
relates closely to the setting of the listed hospital buildings, and to the Drews Pond
Woods local nature reserve. The reserve has an important population of bats, and
this site appears to be an important part of the foraging area, which needs to be
understood before any development is contemplated. A conventional housing layout
of detached or terraced housing on this site would appear very intrusive to both the

setting of the listed hospital, and of Drews Pond Woods.

Site 7 [SHELAA §3374 ] Caen Hill Farm is a long, thin piece between the A361 Bath
Road and the old railway line (both mostly in cutting). It falls about 35m from E to W
and about 10m N-S. Viewed in three dimensions, like Site 3, we believe this site is a
non-starter, because it conflicts with the form of the setting of Devizes (see §2.2-2.3
above), and with sustainable transport objectives. As noted in the Council’s site
assessment, it is open to long distance views along the the A361 route to the W.
Contrary to the assessment, it is in fact also clearly visible from the S side of the Old
Park Valley and the adjacent stretch of Whistley Lane. Development would be very
intrusive in the countryside W of the town, and the topography would be a major
disincentive to walking and cycling. The site also includes a WW2 pillbox, which
should be conserved. The small site at the top of Caen Hill (SHELAA §537) fits into
the topography, but access is highly problematic, due to the excessive length of Avon
Road, as a cul-de-sac.

Site 8 [SHELAA §549] NE of Roundway Park looks logical on plan, but the reality is
that it is part of a large open field separating the built-up area of Devizes from the
hamlet of Roundway. Any development in this space would be very intrusive in the
rural setting of Roundway, and any new landscape containment would take many
years to become effective, in this open context. Development of the identified site
would urbanize a long stretch of Folly Lane, seriously eroding the rural character and
identity of Roundway. The junction of Folly Lane with the A361 London Road is
problematic, because it is only about 100m from the major (now signalized) Windsor
Drive junction. It is already difficult to exit Folly Lane during peak hours. New
housing here is likely to face unacceptable delays accessing the main road network.
Additional Options

3.2.We are aware of several potential development sites in the town, which we believe
are preferable to the identified option sites, because they have less effect on the
open countryside around the town, and are generally more accessible on foot and
by bicycle.
Parkfields (Police HQ) has recently been proposed for housing development by the
Police & Crime Commissioner. This is a much more central location than any of the
sites assessed by the Council, and is easily accessible on foot or bicycle. It also has
easy access to a primary school (next door), to open space at the Sports Club and
Quakers Walk, and to public transport along the London Road. There are road
design issues to resolve, and its yield would be 50-70 homes, but it could make a
useful contribution to meeting housing needs.
Land at Hillworth Road [SHELAA §532] has also been proposed recently. The
housing capacity here is limited by its sensitive location overlooking the Old Park
Valley, and because road access is from what is already a long cul-de-sac. However,
it is much more central than the assessed sites, and has reasonable access to the
town centre by foot and bicycle. Again, it could make a useful contribution to meeting
housing needs.
Wharf and Hospital sites were proposed for mixed use development (including 150
houses) in the Kennet Local Plan. We believe some of the proposed site has been
developed, so the yield will presumably be less than that.

Care Centre Site, Marshall Road has outline planning permission for up to 50
houses.

Conclusion
It appears to us that the least damaging options are Site 5 (N part; Marshall Road -
Sleight Lane), and the additional options identified above, and that they would
together meet the residual strategic requirement of 330 houses up to 2036. The next
least damaging would be Site 4 and the S part of Site 5, both of which are
unnecessarily large to meet the strategic requirement.

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