Widham Farm is now going into its third day tomorrow (Tuesday 24th September 2013). This is the time for local people to come (Cricklade Town Hall at 09:30) to show solidarity with those presenting the case on behalf of Purton. If you wish to speak please register by 09:30 am. Even if just there to listen, it may still be possible to comment occasionally, as the Inspector often asks a general question to which any third party (that’s us) is able to respond.
Below are some talking points to which I will be speaking:
- Housing such as Widham Farm will contribute little to Purton other than more congestion on the oversubscribed roads and out-commuting. In essence Widham Farm would be, simply, a large dormitory, and that is against past and emerging policy. In local terms, Widham Farm will simply exacerbate the congestion of the limited road network and will have no meaningful access to a public transport network. This site is unsustainable.
- The site is outside the settlement boundary as defined by Policy H 3 of the local plan. The currently-emerging Wiltshire Core Strategy also sees no reason to change the settlement boundary.
- Widham cannot be regarded as infill. Wiltshire Council policy is clear, infill is one or two houses slotted in between existing housing and is expected to be within the settlement boundary.
- When this land was first put forward during the deliberations of the North Wiltshire Local Plan many years ago the Inspector at the time did not allocate the site simply because there were other, better, sites available, as there are now.
- The appellant argues that the timing of the emerging Wiltshire Core Strategy should be a key factor in this appeal. They complain about the length of the core strategy process and that it is unlikely to be adopted until late 2013/early 2014. It then speaks to the Neighbourhood Plan and the likely timescales for that. If the applicant was genuinely interested in “sustainable” approaches to community development, it would simply put its interests on hold and await the emergent Core Strategy and a fully-fledged Neighbourhood Plan.
- The emerging Core Strategy recognises that principal urban areas offer the best opportunity for accommodating the majority of future development. That makes logical sense as they have the necessary facilities and infrastructure. Towns (such as Cricklade) should be designated to act as Local Service Centres for the wider rural area and Large Villages in rural areas (such as Purton) should provide for local needs, and, importantly should not be developed as dormitories. Housing development in such villages should be limited in scale and to satisfy local need.
- Turning to the suitability of the site and specifically the environmental and technical aspects of the scheme. Firstly, recall it is outside the settlement boundary and there are far better sites within the boundary. Secondly, the site is not within ready distance (for walking) to the school, pub, the vets, one of the dentists, and none of the chemists, butchers or takeaways. Thus, the site promotes car use. The current bus routes are being consolidated and even in Swindon services are being cut. The notion of a bus service being close by to service the site is aspirational. Most residents would not walk uphill for shopping to the one shop within potential walking distance because they would naturally need a car when carrying heavy carrier bags.
- The appellant notes that both the primary school (St Mary’s) and the secondary school (Bradon Forest) are a further 300 m and 500 m respectively from the junction of High Street and Station Road. The site is simply not accessible to most of the facilities of the village.
- Regarding the flooding to which the site is subject, much has been documented about this on numerous occasions and the parish council and our unitary councillor have provided much photographic evidence at the last appeal and subsequently. The photographic evidence is real and testimony of those who know Widham Farm site is real.
- Since the last appeal hearing, Network Rail has released its plans for the doubling up and potential emplacement of a waterproof membrane under the line hence there will be even more water unable to permeate. They have commented in the 2012 application that they will not accept additional water into their culverts.
- The water that falls onto the fields does not drain into the brook but into the ground so should Widham Farm be built then this water will need to be managed. Establishing a sustainable drainage system requires management in perpetuity and costs in perpetuity. Why build where there will be ongoing maintenance costs for ever. That is certainly not evidence of trying to be sustainable. There are many sites in Purton within the settlement boundary where such constraints and costs do not exist.
- The evidence concerning land use fails to grasp the realities of climate change and that because Widham Farm is simply Grade 3 does not mean that it should built upon by default. In terms of building future resilience, it is imperative that sites for future housing are chosen carefully and with a range of criteria in mind.
- The appellant states that this site is in a sustainable location. There is no such thing as a sustainable location. There are sites that may have more resilience. A report published by Ps and Qs earlier this year called Transforming Purton Parish looked at a range of resilience factors and used dependency modelling to establish which of most of the known potential housing sites in Purton were resilient and would add value to the village and the community. Widham Farm scored very poorly. Widham Farm is not a sustainable location.
- To call Widham Farm sustainable has no validity.
- Whilst the Core Strategy is emerging, the adopted North Wiltshire Local Plan (2011) and its associated development boundaries are the valid boundaries. Indeed, the emerging Core Strategy maintains this anyway, so Policy H 4 (Residential Development in the Open Countryside) has to be the prima facie position regarding new development in the countryside.
- Whilst the appellant tries to argue that the settlement boundary is out-of-date, the Core Strategy clearly reinforces this boundary subject to, and only to, any considerations arising during the course of the neighbourhood plan. That the applicant chooses to try to pre-empt matters by continually bringing up Widham Farm before the Core Strategy and the neighbourhood plan are finalised, is a matter for the applicant’s judgement. It cannot be used as a reason to adjust a boundary where it is currently inconvenient. That is planning anarchy.
- There is a clear intent in the Localism Act (2012) to return decision-making to a local focus and the Wiltshire Council. The Wiltshire Council via its emerging Core Strategy clearly retains the intent of Policy H 4 (Residential Development in the Open Countryside) so the applicant needs to try to work local people and their elected representatives during the core strategy and neighbourhood plan process and not be continually unconstructive.
- The appellant contends that the release of the site is not premature and will not prejudice the emerging Local Development Framework. Wiltshire Council maintains that it is ~ and surely they should know because they are the government’s planning officers.
- The issue of prematurity is satisfied ~ the future shape of Purton will undoubtedly be heavily affected by an ad hoc housing development in the wrong location. This is also supported by a finding in the parish plan whereby most people would prefer development to be within the settlement boundary, where it is known that there is adequate housing sites to satisfy local need.
- The number of houses in this application has reduced during the years down to the now offered 50 houses this is indicative of let us build something at least. We also know the applicant’s intention is to build more (parish council minutes). Fifty houses may or may not be appropriate I just say let us consider that during a proper thoughtful and consultative process (the neighbourhood plan) rather than during the confrontation style of an Inquiry. This should not be how the future of Purton is decided.
- The appellant then complains for the third time that the core strategy and the neighbourhood plan have yet to emerge. A range of circumstances dictate the time for appropriate strategies and plans to emerge, the most important of which is time for consultation. This is a proper planning process. The neighbourhood plan is already in progress it cannot and should not be hurried simply to satisfy those impatient to make money from housing.
- The appellant argues that the appeal site should be released now to meet the housing requirement as identified in the existing and emerging development plan.
- Firstly, this location cannot be considered to be sustainable (thus fails the paragraph 49, NPPF test for reasons given). Secondly, the Policy H 4 currently applies and is reinforced in the emerging core strategy. Thirdly, the continuing reliance on the RSS is tiresome, it was full of flaws when it was going through the Examination in Public and, rightly, has been revoked.
- To argue that the core strategy has not yet been finalised and therefore we should rely on the last publically-tested housing requirement defies common sense. There was a reason the RSS was revoked ~ it was not fit-for-purpose so to rely on elements of it (because it serves the purpose of the applicant) is both illogical and perverse.
- The Inspector’s decision on the Ridgeway Farm appeal stated: “…there is now strong support for allowing local communities to develop their own DP policies, including housing numbers and allocations, within the overarching requirements of the Framework, which require these policies to be realistic and based on sound evidence”.
- The appellant refers to the Purton Parish Housing Needs Survey (January 2012). If one reviews the questionnaire that was used to generate the results of the survey it is clear that the two parts of the survey were confusing and it is not clear that “affordable” was being used in the planning context, rather than the more universal usage … that which can be afforded by ordinary people. The results are therefore tainted by this in-built bias. Consequently, when the appellant seizes on the result that 90.6% of residents answered yes to a lack of suitable existing housing in the Parish to meet their needs, it is not necessarily about affordable housing per se. The appellant makes an unfounded connection then with the total affordable housing stock in the Parish being 12% which is lower than the Wiltshire social housing average of 19.2%. The parish plan results confirm that this misunderstanding is real.
- However, the main point is that the neighbourhood plan must be allowed to emerge so that full consultation occurs, particularly with existing provision of affordable housing. There is a strong indication that all the affordable housing needs could be met by a re-configuration of the existing portfolio. There is a significant danger, that if Widham Farm was approved then it would simply be providing affordable housing for others elsewhere in Wiltshire.
- Of course, any affordable houses should be within the village close to what services there are, rather than on the periphery, away from significant bus routes and outside of effective walking distance.
- The site is not accessible and is a car-owning proposition, there is little prospect of meaningful walking other than for exercise. The neighbourhood plan will determine where new housing will go and it will do that through a proper process of consultation and deep local knowledge. The relentless pursuit of the applicant to build on this land does not reflect support for a strong, vibrant and healthy community rather it has been going against the thoughtful opinions of local people, the parish council, the unitary council and the unitary (and previously as county) council for years and years.
- The appellant suggests that the site has no environmental value because it does not have various Birds and Habitats Directives status or is designated as a Site of Special Scientific Interest; Green Belt, Local Green Space, or is an Area of Outstanding Natural Beauty and so on. Yet it does have value to local people, its open vista, its grazing land, the natural curves of the footpaths and the regular flooding which allows the frequent deluges that we now experience to be held prior to discharge to the local watercourses.
- In summary, the application should be refused because:
- The development is largely inaccessible and is not sustainable;
- The neighbourhood plan should determine where our future housing goes and its nature, based on local knowledge;
- Affordable homes could be met by re-configuring the existing portfolio;
- Land that is less than Class 1 or 2 should not be built on by default, but by proper planning;
- The site is outside the settlement boundary and therefore is not a logical infill;
- There are few demonstrated economic benefits; and,
- The process of endless appeals demonstrates the complete disregard of local people.
The full text is available Widham Farm Dr Richard Pagett 21sep13