Mr A Seaman
Senior Housing & Planning Inspector
The Planning Inspectorate
4/03 Kite Wing
Temple Quay House
2 The Square
Bristol
BS1 6PN
MO.4579/AS/sc
15th March 2013
Your Ref: PINS/Y3940/429/9
Dear Mr Seaman
WILTSHIRE CORE STRATEGY - CHIPPENHAM 2020 STATEMENT OF COMMON GROUND
At the PHM you asked to be kept informed as to our progress in agreeing common ground with
Wiltshire Council (WC).
As background you will have seen the exchange of letters of 13th March between myself and WC
following from my letter of 11th March (attached). This proposed a series of statements in an
attempt to narrow down what we do and don’t agree in terms of fact. Whilst I appreciate both the
volume and the detailed nature of these statements, we strongly believe that if the detail does not
withstand scrutiny, then the decisions that flow from it will be of questionable soundness.
Chippenham 2020 and their agents spent two and a half hours yesterday morning with senior
Wiltshire Council Officers together with two representatives from SKM Colin Buchannon (SKM),
who prepared the Transport Strategy for Chippenham (TSC). Sadly I have to report almost no
progress. WC demonstrated a determination to avoid looking into the detail within the underlying
evidence base. Indeed the Council’s in house Lawyer repeatedly told us that “the Inspector
would only wish to address strategic matters” and that that our suggested statements of common
ground were not relevant to the soundness of the Core Strategy.
Our position, as laid out in our 2012 Evidence Pack, is that the detail is very important, especially
in assessing the Framework (182) requirements of whether the Plan is ‘positively prepared’ and
‘justified’. In considerable contrast, WC refuse to enter into discussion on details and wish to limit
discussion to “broader strategic principles”.
Whilst I am pleased to report that we made some small progress on transport matters and did
agree, with qualifications, 5 points (No’s. 6 to 10), sadly we did not reach agreement on the other
60 points. WC’s reluctance to address them was on the basis that these statements were being
“quoted out of context”.
Please bear with me whilst I use point 6 to illustrate our why we believe that it is necessary to
address the detail. We have understood for a long time that, in arriving at the traffic impact
scores for Option 3 in the TSC, SKM chose to exclude the presence of the completed North/East
Distributor Road in their traffic modelling work. This severely prejudices the results which then
feed through into the SA and thereafter into Topic Paper 12, impacting directly on strategic site
selection. We made our position clear in our March 2012 Evidence Pack and this was re-iterated
to WC at our last meeting on 27th February. We reminded them once again that we had a
documented email exchange with WC Highways Department verifying the factual position on
traffic modelling. Despite this WC, on page 8 (attached) of their “Response to the Opinion of
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Gary Grant of 23rd October 2012” stated unequivocally that “This is not the case and is taking a
single quotation out of context”. They go on to say that the SKM report “is explicit in the fact that
the eastern distributor road had indeed been assessed” and later that the “assessment is
supported by model runs”. Indeed David Milton, through Richard Humphreys QC, gave such
assurances to you at the PHM.
At yesterday’s meeting SKM finally confirmed that, in strict contradiction to the above mentioned
paper and the QC’s assurances, they had not modelled Option 3 with the benefit of the
completed Distributor Road. Further they went on to confirm that the eastern site had been
modelled as a cul-de-sac entered and exited from the A4 immediately to the south and without
the benefit of the River Bridge connecting it to Rawlings Green. In our view this is a wholly
incredulous assumption especially when you look para 3.3 of the TSC which clearly states that
“The development of this site would be accompanied by the delivery of and eastern distributor
road connecting with the road link over the railway line. . . . . . . . . .which would in effect lead to an
eastern bypass to the town from the A350 to the north to the A4 London Road to the east”.
Indeed this has always been seen as the main advantage of developing to the north and east of
Chippenham, thus WC’s “previously preferred option” in 2009. I would also draw your attention to
Figure 6.6 in the same report which shows the bus route entering and exiting over the River
Bridge. When this was pointed out to SKM they suggested that it was an irrelevant detail. The
outcome of these factual inaccuracies is that Option 3 was scored worse than Option 2 for both
Traffic Impact and Public Transport Accessibility whilst evidence supplied by Chippenham 2020
demonstrates the opposite to be the case.
I apologise for exposing you to this level of detail but it is only our perseverance that has led to
WC changing their factual position on traffic modelling and we believe that similar inaccuracies
extend to other areas of WC’s evidence base which feeds into the SA and thereafter into the site
selection criteria employed in Topic Paper 12. By addressing the points in our letter of the 11th
March WC will expose themselves to these other inaccuracies, not least in the SA and the
Consultation process, and this, we believe, explains their determination to avoid this level of
detail.
Since WC will not engage with us to resolve these areas of concern we fear that our wish to
establish the true facts could be potentially disruptive to the examination process. The premise
upon which WC suggested that an Exploratory Meeting was not needed has now been revealed
as being flawed in fact. As a consequence we feel that we must re-affirm our request for an
Exploratory Meeting to resolve these contentious matters at an early stage.
I look forward to hearing from you, and in the meantime will write to Mr Kemp, as requested, by
21st March concerning our attendance at the forthcoming Hearing Sessions. However,
unfortunately we will need to extend to the 3rd April deadline to submit our final submissions.
Yours sincerely,
Michael Orr
DIRECTOR
[email protected]
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MO.4579/GCD/sc
11th March 2013
Georgina Clampitt-Dix
Head of Spatial Planning
Wiltshire Council
County Hall
Trowbridge
Wiltshire
BA14 8JN
Dear Georgina,
WILTSHIRE CORE STRATEGY
In an attempt to fulfil the Inspector’s wish that we should agree as much as possible as soon
as possible, I write to suggest some areas of common ground which we believe would be
helpful to agree at our forthcoming meeting. These are in addition to those already covered
in my letter of 19th February and Owen Inskip’s follow up letter of 28th February.
Underlying the questions are some very simple key points which we believe have been lost
in the volume of documentation presented by the Council:•
Transport is important and, if properly assessed, will have a significant bearing on the SA
and therefore on site selection.
•
Sustainability is important and, if properly assessed, will have a significant bearing on site
selection.
•
Access to secondary school is a key determinant in both Transport and Sustainability
terms and cannot be ignored, and
•
Consultation must be accurately analysed and portrayed if it is to be used to influence
site selection.
The matters below have been identified because it is considered that they should be capable
of agreement. If they are not agreed we will provide a document which identifies them as
such and the Inspector will need to have regard to this absence of agreement in considering
the soundness of the plan.
For simplicity and consistency we have grouped our questions under the headings used in
the Key Issues on pages 5 to 15 of our March 2012 Evidence Pack.
Employment (see summary on page 5 and Appendix 1)
1.
It is agreed that the Town Centre should be the starting point and principle focus for an
employment strategy, as identified in NPPF 23.
2.
It is agreed that that presently the bulk of Wiltshire’s employment opportunities lie in
small businesses with 89% of Wiltshire businesses employing 10 persons or less.
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3.
It is agreed that the Showell Farm employment site is divorced from the town centre of
Chippenham.
Transport and Climate Change (see summary on page 7 and Appendix 2)
4.
Is it agreed that para 6.4.7 on page 35 of the 2009 SA states:“The proposed eastern urban extension could only function if a new distributor road were
constructed, which would also require a new crossing of the London/South West railway
line. Without such a road, access to the site would be inadequate and through town
traffic and congestion would increase. As it is likely that such a new road would need to
be located within land proposed for the northern urban extension, the combining of these
two options appears logical.”
5.
It is agreed that the June 2012 SA states four times at 5.12.29/43/52/59 on pages 97 102 that:- “Transport impact is arguably the key issue with all options being considered”.
6.
It is agreed that SKM Colin Buchannon, in arriving at the traffic impact score relevant to
Option 3 in their Transport Strategy for Chippenham (TSC), chose to exclude the
presence of the north eastern link (7.2.2 and e-mail confirmation) for modelling purposes
7.
It is agreed that the Option 3 has been modelled within the SKM report without the
benefit of the distributor road in place.
8.
It is agreed that Option 1 has been modelled only with the first (northern) part of the
distributor road in place.
9.
It is agreed that Option 2 has been modelled only with the first and second (northern and
north eastern) part of the distributor road in place.
10. It is agreed that the future public transport routes assessed for Option 3 assumes an
internal circular route entered and exited via Rawlings Green and not connecting to the
A4 (see figure 6.6 in the TSC).
11. It is agreed that the assessment of wider benefits does not provide network statistics,
junction statistics for key junctions or evidence in relation to town centre improvements
referable to options.
12. It is agreed that prior to writing the Entran report in March 2012 all relevant modelling
data had been requested by Entran.
13. It is agreed that policy guidance on accessibility is clearly (nationally in NPPF para 30,
34, 35, 37 and 38, and locally including LTP3) to minimise travel by car, encourage
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alternative sustainable modes of transport and minimise distances between new housing
and key facilities such as schools, shops, leisure centres and railways stations.
14. It is agreed that Option 3 (i.e. the previously preferred 2009 Option) scores significantly
better than Options 1 and 2 under Accessibility in the TSC referred to above?
15. It is agreed that PFA’s traffic modelling conclusions found in Appendix 2C and 2D of the
2012 pack demonstrate significant improvement to the average journey time and
reduction in town centre traffic flows by connecting the distributor road to the A4.
Sustainability and Resilient Communities (see summary on page 8 and Appendix 3)
16. It is agreed that that matters of Sustainability are critical to the selection of Strategic
Sites.
17. In paragraphs 7.2 and 7.4, page 24 of Topic Paper 12, it is stated that:“The SA . . . . . . . . . . was unable to recommend one particular site above other options
because one site did not stand out above all others in sustainability . . . . . The larger
urban extension proposals, in the south and east, were very similar in their assessment
scores, and further detailed information would be required to be able to differentiate
further ”
18. It is agreed that the date this statement relates back to is [ insert ]
19. It is agreed that the SA referred to does not consider the eastern site with a reduced
housing numbers option.
20. It is agreed that subsequently the only detailed information provided to the public aimed
at differentiating between the east and south generally has been the January 2012
Transport Strategy for Chippenham (TSC).
21. It is agreed that Chippenham 2020 have provided to the LPA detailed information
including specialist reports on transport, sustainability, flooding and employment which
identifies matters of differentiation between the south and east in March 2012, updated
in October 2012.
22. It is agreed that the only direct comparison of the eastern site against the southern site
in sustainability terms is to be found in App G of the 2011 SA.
23. It is agreed that this comparison was on the basis of the eastern site providing an
unspecified number of homes within a second phase, i.e. East of the River Avon.
24. It has been agreed that in the above comparison the sites scored equally across all 17
indicators.
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25. Is it agreed that the results of the above mentioned comparison fed into the sustainability
scoring of the options in the 2012 SA.
26. It is agreed that this work is summarised in Tables 2 and 3 (pages 23 and 26) in paras 7
and 8 of Topic Paper 12.
27. It is agreed by reference to Table 2 Options 1, 2 and 3 all have 4 double minus (red)
scores but Option 3 only has 3 double plus (green) scores whilst Options 1 and 2 have 6
double plus (green) scores.
28. It is agreed by reference to the scores in Table 2 and how these relate to the scores in
Table 3 that the same -/? score for Flood Risk and Pollution for Options 2 (east) and
Option 5 (south), when added to the scores for Option 1a (north), give single minus
scores for new Options 1 and 2 and double minus for the Previously Preferred Option
(now Option 3).
29. It is further agreed that the same +/? scores for Poverty and Deprivation, Community
Facilities, and Education and Skills for Options 1a, 2 and 5, when aggregated in Table 3,
give double plus scores for Options 1 and 2 and single plus scores for Option 3.
30. It is agreed that Sustainability Specialists, Phlorum, have presented, as additional
evidence, an alternative objective comparison of Options 2 (east) and 5 (south), found in
App 3D of the March 2012 Evidence Pack and summarised on page 27 of Appendix 3?
With regard to secondary schooling:31. It is agreed that both Sheldon and Hardenhuish Schools are full but that Abbeyfield
School has spare capacity and room for expansion.
32. It is agreed that, as matters currently stand, there is therefore a strong likelihood that
Abbeyfield School will be expanded to accommodate the extra school places that arise
as a result of the new housing.
33. It is agreed that a new secondary school place will need to be provided for every 4.5
new homes (ref: para 7, p45, Wiltshire Infrastructure Delivery Plan 2011-2026).
34. It is agreed that that the 2250 new homes provided for in the strategic allocations for
Chippenham will require an additional 500 school spaces.
35. It is agreed that the routes depicted in Map A will be the most likely routes by which
these 500 children can get to Abbeyfield School from the Strategic Sites currently
proposed in the CS.
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36. It is agreed that in the event of deleting the southern housing allocation and allocating
the eastern land for a broadly equivalent level of housing, then children would travel to
school via the route depicted in Map B.
37. It is agreed that under the WC current preferred option it is likely that 500 children will
have to travel through the town centre every morning and evening and that by adopting
the previously preferred option not one single extra child will need to travel via the town
centre.
38. It is agreed that all of the 800 homes proposed to the east of the River Avon under
Option 3 fall within the 1500m “walking isochrone” in the SKM Colin Buchannan
Transport Report.
39. It is agreed that the new NE distributor road could include a dedicated cycle track such
that all the children from the north and east sites will have the potential for a safe and
healthy journey to school.
40. It is agreed that this will contribute to the “modal shift to sustainable modes of transport”
referred to in, amongst other places, para 15, pg 42, Appendix 1 of the 2012 SA.
41. It is agreed that points 31 to 40 above have an impact on one or more of the SA
indicators of Climate Change, Health, Community Facilities, and/or Education and Skill.
42. It is agreed that, as it stands, these factors are not mentioned under any of the above
headings in the 2011 and 2012 SAs?
43. Is it agreed that in the 2009 SA the following is stated (App 4 - p.48):“The LEA has indicated a need for . . . . . . . . additional secondary school provision. The
east urban extension site is in close proximity to an existing secondary school, which
has some spare capacity and development may facilitate additional expansion. Further
modelling work is required. Options 3 and 4 (south) less favoured by the LEA. The
southern site is less well related to an existing secondary school.”
Flood Risk (see summary on page 10 and full Flood Risk Assessment (FRA) submitted in
October 2012)
44. It is agreed that this FRA is an additional piece of evidence conducted by technical
experts on which the Inspector can place reliance.
45. Is it agreed that this evidence addresses any previous concern that the WC had with
regard to flooding and its impact on site selection in Chippenham.
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Town Centre (See summary on page 12)
46. It is agreed that the spatial site selection processes for residential and employment
allocations in the South has not been informed by a Sequential Assessment published or
otherwise.
47. It is agreed that para 5.1.13 of the Wiltshire Core Strategy Consultation states:“A Chippenham Central Area Masterplan will be developed to provide a framework for
the delivery of the aspirations of local people as expressed through the vision
statements for Chippenham”?
48. It is agreed that no such Masterplan has been produced.
Consultation Process (see summary on page 15 and Appendix 5)
49. It is agreed that in Table 4, starting on page 29 of Appendix 3 of Topic Paper 12, is the
Site Selection Analysis which seeks to explain the identification of Options 1 and 2 in the
2011 Consultation Document. This table includes analysis of 11 sites including the East
(Site 3 – Rawlings Farm and Site 4 – Hardens and New Leaze Farm) and the South
(Site 9 – Rowden and Patterdown).
50. It is agreed that this considers sites 3 and 4 together.
51. It is agreed that within Table 5.3 (Chippenham strategic housing options - March 2011)
on page 93 of the 2012 SA, the above sites compare loosely to site 2 East Chippenham
and Site 5 Patterdown and Rowden.
52. It is agreed that the Community Feedback for Sites 3 and 4 (page 38 of Table 4) is
summarised as follows:“During Wiltshire 2026 and since then, the local community have objected to the
proposed allocation and development at east Chippenham because of:
(a) the detrimental impact development could have on the Monkton Park Estate,
particularly in terms of the risk of surface water flooding and the proposed access
route through the estate.
(b) the visual impact of development at east Chippenham on nearby villages with the
Bremhill Parish such as Tytherton Lucas.
(c) the risk of flooding and surface water flooding upstream towards Tytherton Lucas.
A Monkton Park Residents Survey indicated that the issues of most concern for those
who responded was traffic congestion caused by traffic travelling into town via Station
Hill. One of the suggestions during consultation as a way to foster links between
education and employers is to develop a business hub and housing for key workers in
the Abbeyfield School area.”
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53. It is agreed that the Community Feedback for Site 9 (page 50 of Table) is summarised
as follows:“Comments submitted during Wiltshire 2026 suggested that development could take
place south of the town. Additional consultation has taken place since then in which the
desire has been expressed to see employment development and that there may be
opportunities for pockets of development in the Showell Farm area.”
54. It is agreed that the above represents the identified community feedback which
contributed to the subsequent identification of options.
55. It is agreed that on page 55 of Appendix 3 of Topic Paper 12 it is stated (under Site
Selection Update for Chippenham following Wilts Core Strategy Consultation 2011) as
follows:“The responses from the WC Core Strategy Consultation June-August 2011 shows there
is a mix of views about the proposals for Chippenham. There were 550 responses
altogether. 17 of the responses specifically supported Option 1 whilst 8 specifically
supported Option 2. Some respondents although they gave support to either Option 1 or
2, went on to give reasons as to why they didn’t support the options outright. The
majority of the responses did not support either Option 1 or 2 including the proposed
level of development, but some did appear to support specific elements of the proposed
strategy, although they didn’t acknowledge this.”
56. It is agreed that the above is WC’s summary of the 2011 consultation responses.
57. It is agreed that para 9.5 on page 56 of Appendix 3 of Topic Paper 12 lists nearly a page
of objections to development to the south of the town by Laycock Parish Council which
are not reflected or mentioned in the summary’s referred to above.
58. It is agreed that para 9.6 on page 57 lists half a page of comments from Chippenham
Vision, which are not reflected in the summary’s above, including the following:• “A transport mechanism (such as a link road) is urgently required to divert through
traffic to and from the east and thereby relieve congestion and make access to the
town centre easier. Future major developments should be required to enable such a
link and other means for new residents to access the town centre.
• Access to Abbeyfield School is currently poor from the majority of the town. Improved
sustainable transport links from existing and new development are required.
• The omission of the previously preferred Eastern development option needs a much
clearer rationale to illustrate why it is believed to be no longer viable. With the
dropping of the originally preferred East Chippenham Option, the prospect of a northeast link has been removed. Because of the lack of transport analysis, the Vision
does not believe this was taken into account when this option was dropped.”
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Viability and Deliverability (see summary on page 16 and Appendix 6)
59. It is agreed that within appendix 5 in the CH2020 2012 Evidence Pack an analysis
shows that 328 respondents specifically opposed development to the south of
Chippenham, 43 specifically opposed development to the north or east, and 124
specifically supported either development to the north or east, or development which
would deliver a link road around the north east of the town.
60. It is agreed that there is no concern regarding deliverability or viability which has
influenced the decision to discount the eastern site as a Strategic Site.
61. It is agreed that Map C shows the indicative areas set aside for new public open space
under Option 3 to the east and under WC’s current preferred Option 2 to the south.
62. It is agreed that the approximate areas (to be confirmed) shown on the above mentioned
Map show Chippenham Riverside Park (east) to be 43ha and Rowden Country Park
(south) to be 132ha.
63. It is agreed that there is no costed plan for the delivery and ongoing maintenance of
Rowden Park.
64. It is agreed that on page 70, Appendix 1 of the Wiltshire Infrastructure Delivery Plan
2011-2016 the “risk to delivery” of Rowden Park is considered “HIGH” and the reason
given is “lack of resources”.
General
65. It is agreed that Topic Paper 12, page 48, para 3.2 refers to the Council’s previously
preferred North and East Option as follows:“This option was preferred because it provided one main coherent urban extension to
the east and north of Chippenham that would provide a mix of housing and employment,
within close proximity of the town centre and the railway station. It could also enable the
development of an eastern distributor road.”
I hope you will accept these draft statements of common ground as helpful in trying to narrow
down the areas of disagreement between us and we look forward to making progress at our
forthcoming meeting on Thursday 14 March. C2020 remain concerned that the original time
allowance programmed for this meeting has been curtailed and given the extent of issues
arising in this letter, I request that the appointment is reinstated at 09:30-13:00. C2020 will
therefore keep the entire time free for this purpose.
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If there are other agenda items that you would like to address, please let me have them as
urgently as possible.
Yours sincerely,
Michael Orr
DIRECTOR
[email protected]
cc.
Alistair Cunningham
Owen Inskip
Edward Heard
Steven Usher
Rob Williams
Ian Kemp
Wiltshire Council
Chippenham 2020 LLP
Chippenham 2020 LLP
Chippenham 2020 LLP
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