Hilperton slams WC plan

Hilperton thinks Wiltshire Council has failed the people of West Wiltshire when it comes to allocating land for more housing. Here's the parish council's response to the consultation on the WC housing allocations plan:

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Hilperton Parish Council is of the opinion that the Wiltshire Council (WC) Draft Wiltshire Housing Site Allocations Plan is unsound for the following reasons:

Your method of calculating housing requirements for Housing Market Areas (HMA) is improperly based and contains errors.

It seems that WC is using this exercise to improperly avoid due democratic process, and to engineer objectives beyond those required of a housing site allocations plan. An example is the allocation of land for a further 800 homes to Trowbridge (in addition to the 4,790 completed and committed and a further 1,000 'delayed') despite these being in excess of HMA housing needs. This seems to be in pursuit of an ambition, unrelated to housing requirements, to create an ever larger 'Greater Trowbridge' urban settlement.

You have failed to encourage effective use of brownfield sites in accordance with NPPF Core Principle 8.

NPPF Core Principle 8 requires planning authorities to "Encourage effective use of land by reusing Brownfield land." and in Topic Paper 3 you state "during the Wiltshire Core Strategy period (2006-2015) delivery of brownfield sites have contributed 29% of all housing completions". You go on to correctly note the much greater emphasis on brownfield in national policy, particularly in the Housing and Planning Act 2016 and the Housing White Paper of February 2017.

However, beyond these token acknowledgements, your plan fails to consider any measures to encourage effective use of brownfield, especially in the principal settlement of Trowbridge which has acres of derelict former industrial land.

Key documents fail to address brownfield properly or at all. For example, Topic Paper 4states that "There are significant brownfield opportunities that are a priority for redevelopment, although this source of housing land is ultimately a modest proportion of overall supply". You willingly fail to understand that, while this might be true of Wiltshire as a whole, it is far from true for the specific urban context of Trowbridge.

You have failed to include specifically identified sites, which as such are not defined by the NPPF as 'windfall' and are located within the Trowbridge Settlement Boundary.

Namely:- The former West Wilshire District Council Offices, Bradley Road 70 dwellings

East Wing/Trowbridge Hospital/Margaret Stancomb School 300 dwellings

The 'Bowyers' site adjacent to Trowbridge railway station 250 dwellings

Ashton Street Centre 70 dwellings

Conversion of 'The Pavillions', White Horse Business Park 130 dwellings

You have failed to allocate site 256 south of Green Lane for 167 new dwellings.

This site is a logical extension of Trowbridge town which lies between the proposed Trowbridge settlement boundary and Green Lane Wood which acts as an appropriate natural barrier to the urban spread. Further mitigation measures to reduce recreational and other impacts on Bechstein and other bat species in line with existing development permissions and allocations can be satisfactorily achieved.

You have failed to allocate site 292 north of Green Lane for 170 new dwellings.

This site is a logical extension of Trowbridge town which lies between the proposed Trowbridge settlement boundary and Green Lane Wood which acts as an appropriate natural barrier to the urban spread. Further mitigation measures to reduce recreational and other impacts on Bechstein and other bat species in line with existing development permissions and allocations can be satisfactorily achieved.

You have failed to allocate site 3247 Biss Farm for 210 new dwellings.

This site isa logical extension of Trowbridge town which lies between the proposed Trowbridge settlement boundary and the Ashton Park allocation. Part of the Ashton Park development, closest to White Horse Business Park, could be reallocated for employment uses to compensate for the loss of this area as an employment allocation. This would also have the benefit of not reducing the build rate at Ashton Park within the plan period.

You have ignored Planning Examination findings the basis for which have not changed.

Over ten years ago the Planning Inspector determined, in relation to the Hilperton Gap, in his West Wiltshire District Plan First Alteration Inspector's Report:-

"2.2.47. This area so contained comprises a series of small fields, separated by hedges, and crossed by a number of public and other footpaths. From my visits to this locality I consider that at present this area appears as a reasonably homogenous tract of open land, although there are subtle differences in landscape character within it. It is partly in agricultural use and partly consists of unused grassland, but there are views of Hilperton and the edge of Trowbridge from within and across it. I consider that the properties in Wyke Road, Victoria Road and Albert Road form an obvious definition to the eastern edge of Trowbridge hereabouts…

2.2.48. I appreciate that the proposed Hilperton Relief Road is intended to cross this land [the Gap] broadly from north-west to south-east. Although the precise alignment of the road is not formally before me, a draft scheme has been drawn up and was presented to the inquiry. From this and my own observations, I cannot imagine that substantial earthworks would be needed to accommodate the road, wherever its precise route lay, so that its impact in the landscape might not be great. In these circumstances I do not believe that it would, if built here, appear as a more convincing boundary to the town than the existing development…

2.2.49. An alternative boundary to the town policy limit further to the east would enable development to take place on the land so enclosed. This would extend Trowbridge into open land having a reasonably pleasant appearance and would in my opinion harm the semi-rural character and appearance of the area as open fields were replaced by built development of one form or another. It would also erode the gap between Trowbridge and Hilperton…"

You have made unrealistic and unsubstantiated assumptions on building density.

You have proposed sites 263 and 297 for housing stating that these would provide 205 dwellings after numerous mitigation measures. These sites have a combined area of approx. 20.5 ha and thus provide a net housing density of only 10 dwellings per hectare.

This is only about one third of typical modern development density and indicates a highly wasteful use of precious green field space.

HGT Developments llp has applied to develop houses on the northern part of site 263, an area of about 8.5ha partially in a flood zone. After over 18 months of negotiation with WC they are now asking for approval for 170 dwellings. This is a density of 20 dwellings per hectare which would provide, were it to be approved, 80% of the dwellings expected of site 263 on 40% (and the most difficult part) of the site.

WC owns site 297 and has claimed (in Wiltshire SHLAA Appendix 3 for Trowbridge community area) that it alone could accommodate 74 dwellings.

Your calculations are clearly unsound. Either only about one third of these sites is needed to provide the 205 dwellings you claim is required, or you have deliberately underestimated the number that will be built in an obvious attempt to assuage fierce local opposition to development in the Gap.

You have failed at any time to consult with the Hilperton Neighbourhood Plan (HNP) Steering Group.

Your methodology is inadequate and you have failed in your 'Duty to Cooperate' as enshrined in the Localism Act 2011. The duty to cooperate requires additional consultation beyond existing statutory consultees. "The duty requires active and sustained engagement. Local planning authorities and other public bodies must work together constructively from the outset of plan preparation to maximise the effectiveness of strategic planning policies. It is unlikely that this could be satisfied by consultation alone. Local planning authorities that cannot demonstrate that they have complied with the duty will fail the independent examination process". (Paragraph: 009 Reference ID: 9-009-20140306. Revision date: 06 03 2014.)

You have failed to reallocate housing figures within the North and West HMA from Trowbridge to other community areas.

Othetowns have demonstrated an ability to deliver higher than planned completions up to 2017 and can offer sustainable development sites in the plan period but you have failed to consider them.