One of the reasons I became a councillor in Chippenham was to try and prevent the ongoing environmental destruction around Chippenham through cumulative large scale development. Where i’ve failed to prevent the development, i’ve tried to push for the highest possible sustainable construction standards. So I once again experienced that sinking feeling when I saw the planning application for up to 450 houses on land at Showell. Whilst technically this is Corsham without parish, the reality is this is part of the huge urban sprawl in Chippenham.
(The photo above is the current development at Neighbouring Patterdown, the removal of this ancient hedgerow was hidden away in the ecology document agreed at outline planning in 2017).
With all Planning applications the most important thing is to provide evidence in Planning law to support an objection. Whist this is often challenging, we are fortunate to have a professional planning officer at CTC, who gives expert advice.
I spent several days going through the application in detail, and whilst there are many reasons to object, from the energy plan, to cycle and public transport connectivity, to lack of facilities, one thing in particular caught my eye in the Environmental Statement.
The Environmental Statement was commissioned by the developer and noted something I hadn’t seen before, the cumulative ecological impacts from developments already in progress or approved around Chippenham. Here are some of them…
Birdsmarsh 750 dwellings and 2.7 ha of emploment land
Rawlings Green 250 residential developments
Lowden Park 1000 dwelling residential
Hunters Moon 450 dwelling residential 2.3 ha of employment land
Langley Park 400 residential dwellings
Hungerdown Lane 35, Showell Farm 5ha of employment, Patterdown 72 residential developments
Showell nurseries 120 dwellings.
It’s a huge cumulative impact and loss of ecology around Chippenham. Whatever is painted in the illustrative plan in pretty watercolours (and it’s always watercolours), bears little resemblance to the reality of complete environmental destruction in preparation for construction. Yes hedgerow will be planted back, and on paper it may show an increase in biodiversity. But where will the wildlife come from to actually inhabit the newly planted ‘biodiversity net gain’?
At the Town council Planning committee meeting Thursday 13th July, I and fellow councillors were unanimous in our objection to this application. The detailed text can be seen below. Now it’s over to Wiltshire Council Planning.
PL/2023/04417 – Land East of Showell Farm – Object
The site is not allocated for future housing development in the Wiltshire Core Strategy or the Chippenham Site Allocations Plan. It was allocated for mixed-use development (including 196 houses) in the Regulation 18 version of the Wiltshire Local Plan Review in 2021. However, the current version of the Local Plan Review (Cabinet Version July 2023) proposes this site for employment uses only, based on up to date evidence.
The Town Council considers that any planning applications for development on the site are premature as the Local Plan Review needs to first of all determine whether: a) it is suitable to allocate this as a development site, and b) if so, what uses will be allocated on that site. The Local Plan Review has not yet gone out to Regulation 19 public consultation and is still subject to change (and has already changed with regard to uses on this site).
Wiltshire Council’s current acknowledged housing land supply is 4.60 years. Whilst there is currently a lack of 5 year housing land supply, the shortfall is modest and the timing of this proposal therefore appears opportunistic. Housing delivery in Wiltshire, and Chippenham remain strong, with allocations in the Chippenham Site Allocations Plan approved, and Rowden Park being built out. There is no reason to believe that there will be a shortfall in housing supply over the Plan period. Hence, there is no demand for, or benefits of approving additional housing above and beyond existing allocations in the Chippenham area for this Plan period.
CP1 of the Wiltshire Core Strategy sets out a Settlement Strategy for Wiltshire with Chippenham identified as a Principle Settlement. CP2 goes on to detail the Delivery Strategy in this context. It sets out that within the defined limits of development there is a presumption in favour of sustainable development. However, the site is not located within the limits of development of Chippenham, being an open countryside location outside of the defined limits of development. CP2 is very clear that development will not be permitted outside the limits of development. The development is therefore in conflict with CP2, and Core Policy 10 which identifies a quantum of housing for the Chippenham Community Area up to 2026.
Recent planning appeals in Wiltshire have considered, where there is a modest shortfall in housing land supply, how well related the site would be to the settlement boundary and the existing built-up area when determining how much weight to attribute to the conflict with CP1 and CP2 of the Wiltshire Core Strategy. It is clear that the site-specific circumstances in simple physical and spatial terms, needs to be taken into account. In this case, the site does not adjoin the settlement boundary and whilst the site is adjacent to the Rowden Park/Showell Nurseries sites on one side, on all other sides, the site is surrounded by open countryside. The proposed ‘ribbon development’ would create an obvious and isolated urban incursion into the countryside and at this current point in time would not appear as a logical, sustainable, expansion of Chippenham, having the following adverse effects:
The design and isolated location of the site would not encourage walking opportunities. The town centre would be over half an hour’s walk away, the nearest primary school (new school at Rowden Park) located 19 minutes walk away and nearest secondary school (Sheldon School) located 50 minutes walk away. None of Chippenham’s existing health, education or community facilities would be located within a 15 minute walk for new residents of the development. With no health or education facilities proposed on the site, the development would not constitute a sustainable ‘15 minute neighbourhood’ and would be wholly reliant on the private car to access other services and facilities in the town. Travel times to facilities have not taken into account topography, which has a limiting factor on distances. i.e. the nearest GP is accessed up a hill. Also no account has been taken as to whether there are any pedestrian/cycle facilities along routes. Figure 6.1 of the Transport Assessment implies that people can cycle or even walk along the A350.
This is a greenfield site where there are limited site constraints that would justify not incorporating segregated cycle paths, as per the guidance set out in Summary Principle 2 of LTN 1/20 which states that ‘…On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians…’
The layout and design of the proposed development would result in very poor permeability between the site and its surroundings, namely:
A cul-de-sac design with a single vehicular access off the B4528 into the site appears wholly inadequate to serve 450 dwellings. With no priority junction for residents to enter or leave the site, the development is likely to result in traffic congestion around the junction with the B4528. At the very least there should be a second vehicular access into the site, or the main vehicular access located off a new main road/distributor as envisaged in the Local Plan Review
There are no vehicular linkages into the Rowden Park or Showell Nurseries sites immediately adjoining to the north. There is also poor pedestrian permeability between the site and its surroundings, with only one pedestrian connection into the Rowden Park site. The residential plots proposed to be located in the north eastern finger of the site would be particularly isolated from both the B4528 and the adjoining Rowden Park site to the west (residents would have to make a large detour to access the adjoining Rowden Park site via the one pedestrian link between sites)
There is a missed opportunity to provide a segregated cycle path through the riverside country park (and linking into proposed cycle paths through the country park), making for the shortest and the most direct connection from the site to the town centre via active travel modes
The location of the ‘local centre’, at the edge of the development, would be unlikely to meet the shopping, leisure and community needs of the whole estate. It would be better sited at the heart of the development, as a focal point for the community, and within easy walking distance for all residents.
No buses are proposed to route through the site, despite the scale and remoteness of the central/eastern parts of the site to the B4528. CIHT ‘Buses in Urban Development’ recommends that the maximum distance to a bus stop should be 300m for less frequent routes, 400m for frequent routes (every 12 minutes or better) or 500m to key bus corridors with two or more high frequency routes.
The submitted Energy and Sustainability Statement is generic and non-committal, with decisions on low carbon energy features for houses left to post-planning stage. Modelling should be undertaken to inform the energy efficiency of the proposed houses, and used to inform the outline design work and quantum of development on the site to provide a high quality sustainable scheme. Electric vehicle charging, heat pumps, solar panels, solar gain, and cycle storage, all require space or optimal building orientation, and will ultimately impact on the quantum of development that can be provided on the site.
There would be no on-site provision for sports facilities, to meet the demands of new residents.
There would be no education or health facilities on the site, to meet the demands of new residents, contrary to Core Policy 3 of the Wiltshire Core Strategy.
There would be a loss of high quality agricultural land (Grades 1 and 2) on approximately half the site. The Environmental Statement considers this a ‘moderate adverse effect’.
The Environmental Statement explains that there would be ‘major/moderate and significant adverse effect’ on landscape and visual impact on the site itself, ‘significant adverse effects’ to users of the public rights of way as they pass through the site, a ‘major/moderate level of effect which is significant’ on the nearest residences, and a ‘moderate adverse level of effect which is significant’ on the remaining residual receptors. The proposal would therefore have an adverse impact on landscape and visual impact, contrary to Core Policy 51 of the Wiltshire Core Strategy.
In conclusion, this premature development proposal would conflict with Wiltshire Council’s spatial strategy for the location of housing and undermines the plan-led approach to sustainable development and would therefore conflict with the principle aims of the NPPF. As such, when also considering the housing shortfall is modest, the weight to be afforded to the conflict with the development plan housing policies is considered to be significant. The Town Council considers that the adverse impacts of the proposal as set out above would significantly and demonstrably outweigh the limited benefits of the proposal, under the application of the ‘tilted balance’.