LATEST NEWS: An extension of time on this Planning Application has been agreed to the 28th August
- YOU CAN CONTINUE TO COMMENT!
At some point in this period it will almost certainly go to a Planning Committee and that’s what all of our comments and efforts ultimately were aimed towards.
Thanks as always for your support in opposing this inappropriate application.
Your Ridgeway Ward Councillor
Comments submitted by SBC's Landscape Architect on the Inlands Farm Application:
My previous comments remain unchanged: ‘The application depicts a development of substantial scale, in a sensitive rural location, which would create an unacceptable urbanisation of existing countryside.
This would be detrimental to the rural setting of Wanborough and the protected setting of the North Wessex Downs Area of Outstanding Natural Beauty that abuts the site to the south, and the planned NEV.
Both phases of the application, or either phase if considered individually, are markedly incongruous in this location, presenting harmful and overwhelmingly adverse visual impacts.
The applicant has incorporated various techniques to minimise this impact, but visual mitigation can only achieve limited results as clearly shown by the submitted 3D views.
Comments submitted to the revised application at Inlands Farm by SBC's Conservation Officer:
Conclusion: I have given consideration to the preservation and enhancement of the character and appearance of the conservation areas and the significance of designated heritage assets, including their setting.
On balance, I do not consider that there is ‘clear and convincing’ justification for the harm caused as required by Paragraph 194 of the Framework.
I have concerns from a conservation perspective regarding the principle of such a development and its impact upon the character and appearance of the conservation area and the setting of designated heritage assets.
In this case I would recommend refusal on the following basis:
The proposed hybrid application which contains full application for 33,507Sqm of industrial use and an outline application for 48,681 Sqm, a result of its siting and location on an open parcel of land within the open countryside would result in an incongruous, prominent form of new development that would have an unacceptable urbanising effect by way of visual intrusion and unacceptable encroachment into the rural landscape setting which results in harm to the setting and context of surrounding designated and non-designated heritage assets.
The proposal would therefore fail to provide a scheme which 2 Paragraph: 013 Reference ID: 18a-013-20190723, Revision date: 23 07 2019 Conservation Comments Masterplanning, Design & Conservation Team Planning Department, Swindon Borough Council Planning Ref: reinforces local distinctiveness, preserves or enhance the tranquillity, amenity and traditional quality of the landscape setting and fails to make a positive contribution to the locality which would outweigh the harm caused.
The proposal is therefore, contrary to the duties under S66 and S72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, Local Plan Policy EN5, EN10 and the heritage policies of the Framework.
Normally I would seek to suggest amendments which may overcome any objections, however on this occasion, the principle of such a scheme is clearly inappropriate from a conservation perspective.
Whilst the scheme is presented as a ‘science park,’ in reality after Phase 1 and 2 were implemented, the science park component would contain 32,281Sqm of floorspace, roughly 40% of the entire floorspace. Realistically the site will be an industrial site which takes up 60% of the use with an ancillary ‘science park’.
As the proposed 'Science Park' immediately adjoins the Area of Outstanding Natural Beauty I thought I would share a useful extract from:
'NORTH WESSEX DOWNS AONB POSITION STATEMENT'
(Development Affecting the Setting of the North Wessex Downs AONB)
1. Areas of Outstanding Natural Beauty (AONBs) are designated by the Government for the purpose of ensuring that the special qualities of our finest landscapes are conserved and enhanced. In planning policy terms they have the same status as National Parks.
2. The primary purpose of the North Wessex Downs AONB is to conserve and enhance the natural beauty of the AONB. The AONB also has secondary purposes to increase awareness and understanding of the special qualities of the AONB, to take account of the needs of agriculture, forestry and other rural industries and to foster the social and economic well being of local communities and those who live and work in the area.
3. The setting of the North Wessex Downs AONB can be explained as being the surroundings outside the AONB and although outside its boundary its extent is not fixed and may change over time. Elements of a setting may make a positive or negative contribution to the AONB, it may affect the ability to appreciate that significance or may be neutral. For the purposes of spatial planning, any development or change capable of affecting the significance of the AONB or people’s experience of it can be considered as falling within its setting.
4. The surroundings of the North Wessex Downs AONB are also important to its landscape character and quality. Views out of the AONB and views towards or into it from surrounding areas can be very significant. Development proposals that affect views into and out of the AONB need to be carefully assessed to ensure that they conserve and enhance the natural beauty and landscape character of the AONB.
To be very clear, both Robert Buckland as your MP and I as your Borough Councillor continue to object to this application in this location. My comments as submitted are below:
Swindon Boroough Council
05 June 2020
I am objecting to this revised application as a resident of Wanborough and as the Ward Councillor for Wanborough.
Planning Policy: The site remains outside of the adopted Local Plan (for development purposes) and was specifically rejected from inclusion in the Draft Local Plan, which has been through both the Regulation 18 & 19 Statutory Consultations.
Part of the Local Plan review process was the SHELAA (Strategic Housing & Economic Land Availability Assessment) and this site was expressly rejected in that process as unsuitable.
The Draft Local Plan has identified sufficient land for the economic needs of the Borough and they have also taken steps to safeguard the employment use of the Honda site which will close in July 2021.
No Planning Policy can cater for the very specific whims of an applicant, which in this case have been drawn so tightly that only one site could every fit their criteria.
For Swindon Borough Council to reject their own Local Plans would be highly unusual. This site was designated as an ‘Area of Non-Coalescence’ at the 2015 ‘Local Plan Inquiry’, to mitigate the 8000 home ‘New Eastern Villages’ development. That planned allocation already included a 40ha employment site (which incidentally this applicant rejected due to tenure) but is likely to be built and occupied within 18 months.
Whilst I am very supportive of the applicant and his business, their use is a small part of this site (although highly visible). The contrived ‘needs list’ and the ‘alternative sites’ study carried out by the landowner’s agent (rather than an independent and objective third party with suitable specialist knowledge) is meaningless.
It is designed around giving one possible answer. Wasdell require a much smaller site for their business. That need is not objectively assessed in the application.
As this proposal is not for housing, our Local Plan can be considered ‘up to date’ and is fully relevant in assessing this application.
Phase 1: The application suggests long term maturity of planting, but it is undeniable that the ‘setting’ of both the Conservation area of the village of Upper Wanborough and the rural setting to the North Wessex Downs AONB will be changed forever.
This is a principle issue as the site slopes up towards Upper Wanborough and the AONB and therefore the views from and to these protected features will be a key issue.
Because the applicants have chosen to give certainty in only one aspect – ‘Phase 1’ then that is the visual impact we must address first.
The Phase 1 building will be a dark mass encircled by a HGV access road around the building - meaning that lighting (when viewed from the AONB and the Conservation area will be an issue) as well as noise.
Planting to the western main approach would be new. This will not hide the building for decades and that will lead to the alien building concealing the hilltop village.
Access: The application claims early delivery of the roundabout section at the intersection of Pack Hill and the Southern Connector Road. This road is already fully funded and the section within the application boundary was already being delivered following the CPO Inquiry.
The ‘claim’ to be delivering a cycle path is untrue as it already being delivered by the SCR project and fully funded.
The Southern Connector Road is a strategically well-planned single carriageway road with a soft edge and with cycle paths and pavements and is only planned as an access for around 1/3rd of the residential only traffic of the New Eastern Villages.
Any additional burden on this road may lead to drivers choosing alternative routes in contravention of the Borough policy to minimise rat running in Wanborough and nearby villages.
A 24/7 distribution and manufacturing warehouse added to the SCR will lead to many additional vehicle movements which make both the cycling and pedestrian connectivity being less attractive. Delays at Commonhead roundabout as a result of both employee traffic (the applicant suggests a doubling of existing employees to 1200) on top of the 230 suppliers delivering in and the 85% of deliveries out heading to Heathrow for export. That is only phase 1.
This proposal: The ‘Science Park’ is an Outline Application, but the attractive ‘green spaces’ are contained largely within that area. Views from the Marsh towards the AONB or from the Southern Connector Road are only mitigated in that 2nd phase outline which may never be delivered.
CAM-Sci have delivered a glossy report which discussed possibilities – they have not been commissioned to deliver the Science Park themselves and alternative Science Parks away from educational institutions such as Porton Down have required tens of millions of pounds of subsidy to deliver any notable employment.
About the location: Inlands Farm is established good arable farmland, rising in the East to the Upper Wanborough Conservation Area and to the South ‘Pack Hill’ which forms the boundary with the Area of Outstanding Natural Beauty (AONB). The AONB as well as the 'setting' of the AONB have national protection. For this reason, applications close to Lydiard House (for example) have been refused because often the 'setting' is as important as the designated asset.
The 'setting' of the hilltop village and Conservation Area of Upper Wanborough has designated significance (as evidenced in previous appeal decisions) and few people would argue that the village (when viewed from the area around 'Great Moorleaze' at the entrance to the AONB) would disappear behind the industrial building and its attendant lighting, noise and infrastructure. The Grade 1 listed church at St Andrews is the most prominent part of the skyline as well as the more distant Liddington Hill and Castle.
About 80% of the site sits in the Area of Non-Coalescence designed to protect Wanborough, the AONB and other villages from coalescing with Swindon. It is an open landscape with few major trees for example meaning that anything which is built will be obvious.
Applicants Landscape Plans: The Landscape plans indicate that in the 40m strip of land between the AONB and the building there will be a road, two sections of tree planting, a ditch and an ‘attractive’ pedestrian route.
The problem with trees required to hide a 14.5m building are that they grow in height and width – this means that the attractive pathway will be in shade and will need to be lit as well as the vehicular access – all adding to light pollution. They also are not in leaf all year round.
The landscape assessment specifically references viewings out from the Conservation area but do not address the views towards nor the ‘setting’.
The applicants own ‘Landscape & Visual Amenity Report states:
• Two adjoining blocks of recently planted woodland on the south side of Pack Hill (opposite the Site) would mature to form a new woodland block on the northern edge of the North Wessex Downs AONB. This will provide substantial enclosure to the south side of the Site and separation from the AONB.
What this ‘expert report’ fails to note is that those woodland blocks ARE the AONB.
Flooding: The site is notable for ground water flooding. Water flows across the land resulting in considerable fast-moving flows at the entrance to Inlands Farm and which discharge into the roadside ditches heading North along The Marsh.
Flooding increased in recent years due to less deep ploughing of the land and it is difficult to see how the ‘developed’ site would better this situation.
The Environment Agency notes that they do not record surface water flooding which occurs across this site and we have photographs from this year which inform.
Water Supply & Sewage:
In a belatedly updated comment Thames Water confirms there is insufficient FOUL WATER capacity to serve a commercial building larger than 625sq.m (The Phase 1 proposal is 33,000sq.m).
They also confirm a water supply deficiency for Phase 1 (and any additional buildings beyond 23,000sq.m
For the Planning Authority the consideration should be whether this identified deficit in a basic facility to serve the development will make other Phases of the NEW EASTER VILLAGES unviable in the short term as the capacity identified for residential development may be taken away by this un-planned development.
1) This site is not allocated for development - housing or employment. It is largely with the SBC designated 'Area of Non Coalescence' and the 'setting' of the North Wessex Downs Area of Outstanding Natural Beauty'
Policy NC3 in the Local Plan states (bullet E): The character and identity of Wanborough, Bishopstone and Bourton will be protected by a principle of non-coalescence between the settlements. The land between the New Eastern Villages site boundary and the existing villages shall remain part of the countryside. However, small scale development within this area, as defined on the Policies Map, will be permitted where it retains or enhances the existing character of the countryside and involves the re-use, conversion or extension of existing buildings at a scale appropriate to their location, in accordance with the criteria specified in Policy DE1; or is an essential requirement directly related to the economic or social needs of the rural community.
2) Policy EN2 in the Local Plan states 'Swindon Borough is set within a beautiful landscape context including the North Wessex Downs Area of Outstanding Natural Beauty'.
3) Policy EN5 in the Local Plan states 'The North Wessex Downs Area of Outstanding Natural Beauty (AONB) is a nationally recognised area of landscape protection. Proposals within the Borough which are within and or abuts the North Wessex Downs AONB must accord with relevant criteria set out in the AONB Management Plan and paragraph 115 and 116 of the NPPF. Proposals outside the AONB should not adversely affect its setting.'
Policy EN5 further states 'In meeting the requirements of EN5a, applicants for development should demonstrate how they have taken into account Landscape Character Assessments and assessed the potential impact of the proposal upon the following attributes of the landscape: existing landscape form, features, topography and character; the contribution of the landscape to biodiversity and wildlife; local geology and geo-diversity; views, visual amenity and the landscape setting;
Biodiversity - locally distinctive and characteristic pattern and species composition of natural features such as trees hedgerows, woodland field boundaries watercourses and water-bodies;
Geology - locally distinctive and characteristic landforms and topographical features throughout the Borough such as locally important views, visually sensitive sky lines, ridges and valleys;
Views both in and out - visually sensitive skyline, geological and topographical features; and the separate identity of settlements and the transition between man-made and natural landscapes at the urban fringe.
I would like to remind those considering the application that SBC has obligations regarding the AONB as part of ‘our’ management plan – which we are obliged by Government to produce and to which we should have due regard in considering applications both within, and in the setting of the AONB.
NPPF policy on AONBs:
116. Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. Consideration of such applications should include an assessment of:
• the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
• the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
• any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.’
Has the duty to have regard to the statutory purposes of AONBs to ‘conserve or enhance the natural beauty of their area’ been carried out? This often-overlooked legal requirement is to consider whether an AONB will be ‘enhanced’ by a proposal as well as ‘conserved’ by it.
The North Wessex Downs AONB lies to the south, partly within Swindon Borough. Its landscape is predominantly a chalk land landscape of scarp slopes and moulded dip slopes that reflects the underlying chalk geology.
National guidance has confirmed that great weight should be given to conserving landscape and scenic beauty in AONBs which have been confirmed as having the highest status of protection in relation to landscape and scenic beauty.
AONBs are protected under the existing statutory requirements of the Countryside and Rights of Way Act 2000, specifically under Section 85 it is a legal duty for all relevant authorities to have regard to the primary purpose of AONBs to conserve and enhance the natural beauty of the area.
The potential for harm on the setting of the area from large-scale urban extensions is substantial. Any new uses or development proposed outside but within the setting of the area should consider the North Wessex Downs AONB Position Statement on Setting.
Proposals should include detailed measures to mitigate against harm on and into the area. Forms of mitigation may include strategic landscape buffers, restrictions on building heights, care over massing and scale, care over roofscape design, or avoidance of development in the most exposed locations.
The North Wessex Downs AONB Management Plan includes a policy paper on ‘settings’. The management plan is likely to be a material consideration in planning decisions.
The AONB ‘Setting Position Statement’ couldn’t be clearer - Paragraph 5 copied below it is difficult to see how each of these is not relevant to this application:
5. Examples of adverse impacts on the setting of the North Wessex Downs AONB could include:
• development which would have a significant visual impact on views in or out of the AONB;
• breaking the skyline, particularly when this is associated with developments that have a vertical emphasis and / movement (chimneys, plumes or blades for example);
• loss of tranquillity through the introduction or increase of lighting, noise, or traffic movement or other environmental impact like dust, vibration, spatial associations and historic relationships; • introduction of abrupt change of landscape character; • loss of biodiversity, particularly if of habitats or species of importance to the AONB;
• loss of features of historic and natural landscape interest, particularly if these are contiguous with the AONB;
• change of use of land such that to cause harm to landscape character; and
• development individually or cumulatively giving rise to significantly increased traffic flows to and from the AONB, resulting in loss of tranquillity and erosion of the character of rural roads and lanes; • Increase in air and water pollution.
NPPF paragraph 115 requires that in any decision “great weight should be given to conserving landscape and scenic beauty” in AONBs.
This applies not only to developments proposed within an AONB but if proposed in its setting such that the AONB would be affected.
The height of the hurdle to be crossed by the ‘great weight’ requirement is a matter of judgement in individual cases, but the High Court has clarified that it must be taken seriously.
Would the development be ‘major’ development within the AONB for the purposes of applying NPPF paragraph 116? I believe it would be.
If the development is ‘major’, permission should be refused unless the two requirements in paragraph 116 have been met. These are that there are ‘exceptional circumstances’ to justify permission and that the development is ‘in the public interest’.
My Comment: This is the model which Wasdell identified as a block to them moving to somewhere like Symmetry Park where ‘freehold’ and flexibility in design’ were not available.
As a resident of the village and as the elected representative of the residents of Wanborough, and the area in which this scheme is proposed I would urge refusal.
The site is not in accordance with local or National Planning policy, genuine alternatives are available if an employer is open to those alternatives. In this case we are on one hand being shown and employer who is undoubtedly important and on the other a speculative application to turn unallocated farmland into development land.
Finally, I reserve the right to make additional comments as corrected documents are added to the planning portal and critical matters including Highways modelling remain outstanding.
Ridgeway Ward Councillor & Resident.
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