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...the response from the Hilperton Gap Action Group.
HGAG is not bound by the etiquette that Wiltshire Councillors, and parish and town councils, are expected to abide by...
Having said that, I fully endorse the following comments and, again, I wonder exactly which planet the spatial planners at County Hall inhabit. Surely the time is coming when a 'new town' somewhere in Wiltshire is the answer rather than continuing to tack more and more houses onto existing towns but with no infrastructure to support them.
I regret that I cannot show the tables referred to below but the full reply can be found on the WC consultation portal.
1. Do you agree with the proposed scope of the Swindon and Wiltshire Joint Spatial Framework
No. We are exasperated with trying to untangle your dense thicket of planning documents that overlap and sometimes contradict one another. Much of the content, although dressed up in complexity, actually consists of abstract aspirations and lists of theoretical policies that provide no practical benefit for real people. You purport to be planning for ‘homes, jobs and infrastructure’ but of course you will be delivering almost none of these yourself and you have only limited influence over developers and employers that may or may not choose to do so. We say that it would be much better to recognise the limits of what you can do – and do it well – rather than pretend, via a mountain of fake processes and pointless documents, that you can achieve an imaginary grand design.
In your Swindon and Wiltshire Joint Spatial Framework: Issues Paper (at Appendix 1) you set out an 11-stage programme of work that you have commenced in order to extend the Wiltshire Core Strategy (now renamed the Wiltshire Local Plan) to 2036.
You have called this work the Local Plan Review and you provide a timetable for it at Table 2.1 of the SWJSF Issues Paper. Unhelpfully, you have not cross-referenced the programme stages to the timetable so we have added these in red below. We have also added two other work streams that you have going on at the same time. This table, as we have revised it, shows that all four work streams are apparently determining, at the same time, where development will be allowed.
1. The Local Plan Review will in Q3 2018 select preferred sites for development.
2. After this, in Q1 2019, the Joint Spatial Framework will identify broad locations for development. We ask: What is the point in identifying broad areas if specific sites have already been identified?
3. Meanwhile, the Wiltshire Housing Site Allocations Plan (WHSAP) will by then (Q4 2018) have confirmed what sites are allocated for development. We ask: Will this examined plan be ignored by (1) and (2) above or render them redundant?
4. At the same time the Strategic Housing and Land Availability Assessment (SHELAA) will go through annual iterations to select available sites. The SHELAA seems to live in a different universe to WHSAP. We ask: Which one will prevail?
One power you do have, which local people do actually care about a great deal, is the power (subject to appeal) to approve or not approve whether a development will take place on a particular parcel of land. And yet rather than ensure a clear route to these decisions you have a created a swamp of conflicting strategies, policies, plans, assessments and guidance that almost seem designed to advantage manipulative speculative developers over ordinary citizens.
An example of this is the major formal consultation on the Council’s 4,500 page Wiltshire Housing Sites Allocation Plan (June 2017). This plan concluded (in the Trowbridge CA Topic Paper p.16) that site no. 293 (Land to the east of Elizabeth Way) is not suitable for development because “The site has a number of issues that may not be capable of mitigation.” Hundreds of local people made representations that the Gap should not be built on and the plan, we expect still excluding site 293, will go forward to an examination in public by a planning inspector next year.
But you have now produced a further report, without consultation, called the Strategic Housing and Economic Land Availability Assessment (November 2017) which says (Appendix 5.17 Trowbridge CA p.90) that site 293 is ‘Suitable, Available, Achievable, Deliverable, Developable. No constraints.’ Further, you fail to acknowledge that this site has been dissected and partly occupied since 2016 by Elizabeth Way. We ask: How can it possibly be good planning, in the service of the community, to have two assessments saying precisely the opposite of each other?
2. Do you agree with the proposed objectives for the Swindon and Wiltshire Joint Spatial Framework?
You state (para 2.6) five objectives for the Swindon and Wiltshire Joint Spatial Framework which, put in simple English, are to achieve:
1) A home for everyone who is expected to need one.
2) Enough land for all business activity.
3) Infrastructure and services to meet all local demand.
4) The best possible environment.
5) People using buses and trains rather than cars.
You state (para 2.1) that this document will have no bearing on planning decisions, the one concrete power you do have to shape our community.
We say that these are longstanding worthy objectives but that producing yet another planning document (on top of the hundreds that you and your predecessor councils have produced since 1945) will do nothing to bring them about.
3. Do you have any comments on the findings of the Swindon and Wiltshire Strategic Housing Market Assessment (SHMA)?
We welcome your review of HMAs and can see that the new areas are based on a detailed consideration of the factors and patterns influencing housing need. However, entirely new Housing Management Areas have been invented that bear no relation to those used in the Wiltshire Core Strategy/Local Plan and you do not provide any reconciliation of the two sets of data. We say that this prevents comparison between the SHMA and the current Local Plan. Once again you are publishing parallel inconsistent reports that cause confusion.
You say in the Trowbridge HMA Profile (p. 3) that; “The Strategic Housing Market Assessment 2017 (SHMA) identifies the need for housing in this market area over the period 2016-2036 to be 13,500 dwellings.”
• This number has been rounded up – the actual number in the consultants’ report (Figure 69) is 13,312
You continue in the Trowbridge HMA Profile (p. 3): “This would represent an increase on the Wiltshire Core Strategy (WCS) period 2006-2026.”
We say that you present no evidence for this that we can find. The SHMA is constructed entirely on the basis of the new HMAs (‘Trowbridge HMA’) and not those used in the Core Strategy/Local Plan (‘N&W Wilts HMA’). No reconciliation is provided of how these entirely different areas are related.
4. Do you have any comments on the findings of the Functional Economic Market Area Assessment?
You have employed consultants to forecast how much employment land will be needed over the next twenty years. In their FEMAA Report (table 6.4) they have made assumptions projecting historical patterns of local business mix, homeworking, floor space required per worker, how much stock will be replaced etc. etc. In 210 pages, the analysis concludes that between 8.3 and 20.8ha of land will be needed for office space and 83.1ha will be needed for industry across a vaguely defined area in W Wilts of approximately 2 million hectares.
We say that the actual demand for industrial space to 2036 will be driven mainly by the future national economy, by technological development and by a myriad of unpredictable interacting micro-economic business decisions. It is spurious to pretend to project future need for land, to the nearest 1,000 sq metres, based on historical patterns.
We say that the analysis is pointless in any case because it is entirely detached from actual planning decisions about what office and industrial sites should be permitted, the only influence you actually have in this matter.
5. Do you consider that the methodology to test growth in each Housing Market Area and each Functional Economic Market Area is robust?
We assume that you are referring to ‘Stage 5c’ of your programme of work in Appendix 1 of the SWJSF.
We say that it is misleading for you to imply any kind of replicatable method for a process of “comparative assessment against the sustainability themes”. The output of this process will be mostly personal value judgements by your officers which cannot be proved right or wrong.
6. Do you think the vision for the role and function of each settlement should change?
We do not see this as a meaningful question.
We say that the role and the function of a settlement is rooted in long history and evolves over generations of complex human activity. We do not see that a ‘vision’ in a transitory report will have much influence on this. Also, change is brought about by leadership, not by writing strategies.
7. How should the Councils respond to the strategic issues for each Housing Market Area?
In Trowbridge HMA you put three questions about the town:
1) Is the town sufficiently attractive to inward investment to support its current role as a main focus for growth in Wiltshire? What could be done to improve its attractiveness?
2) Environmental constraints may limit potential for additional land for employment and housing, should the extent of the Green Belt be reviewed?
3) Are there further brownfield opportunities for redevelopment that can make significant improvement to the town and the vitality and viability of the town centre in particular?
We say that it is astonishing, after decades of decline in Trowbridge since the end of manufacturing, that your analysis of the problems is apparently at such a superficial level. We understand that what you are actually raising is;
"1) We have already decided to load our homebuilding targets onto Trowbridge but business does not want to come to the town to provide jobs and shops. Can we get away with this and build all the houses anyway?
2) The big developers who control all the potential development sites around the town say they would prefer to build in the Green Belt and will not commit to building homes any time soon at West Ashton. How can we help them build houses where they want to?
3) We know very well that parts of Trowbridge town centre have been semi-derelict for years (we drive past them every day) but we wish to virtue-signal that this matters to us, even though we have few powers or much interest in doing anything about it."
We absolutely oppose any moves to weaken Green Belt protection to the north of Trowbridge.
8. Are there any development constraints that should be taken account of?
We say that it is quite astonishing that, after decades of work on dozens of plans, strategies, frameworks, assessments, visions, etc., etc. you should not already have a very detailed understanding of the constraints on development in and around Trowbridge. The few cursory pages in the SWJSF Trowbridge HMA Profile do not even begin to provide an understanding of these.
9. Are there any development opportunities that should be taken account of?
We say that you know it to be vanishingly unlikely that this question will elicit workable proposals that have never in the history of planning in the town been conceived of by yourselves, Trowbridge TC, landowners, developers, businesses, lobby groups and others. It is therefore a pretend consultation question.
10. Do you have comments on the advantages or disadvantages of different concepts for growth alone or in combination?
In Trowbridge it was long ago decided to expand the town by urban extension and thousands of hours of officer time has been expended on this concept.
We say again that you have again failed to explain why there has been “complexity and delay developing Ashton Park; a south eastern urban extension to the town for 2,600 homes.” We are fairly confident that the delay is due to developer reluctance to proceed while there remain prospects for more profitable development at Southwick and in the Hilperton Gap. We ask you to give detailed evidence of what “complexities” exist at Ashton Park (but not at other sites around Trowbridge) and why you are still unable to resolve them after years of work.
We also favour expanding urban capacity in Trowbridge by redeveloping derelict sites, converting some now inappropriately located industrial sites and changing some over-provided retail sites to housing.
11. Do you have any further comments
More than we can even begin to write down.