Formula Land Community Consultation
Copies of a public consultation leaflet
(example here)
are currently being distributed to houses in the village. It is asking Downton residents for comments on their proposal to build
around 100 houses on the Breamore Road site, south of
Catherine Crescent.
Please note that the consultation deadline is 12th April. As this includes the Easter period, time to respond is short, especially if
the leaflet is returned by post (an online response option is offered on their website
www.breamoreroad.co.uk)
It is important that your response to this consultation reflects your own views, but you will want to ask yourself about the effect
100 houses could have on you, your neighbours, and on the village. You may want to consider some of the things are included in
the list below:
- Wiltshire Council’s Local Plan Review Consultation is not due to report until the end of the year. This will assess housing need
throughout the county and determine in detail what areas need housing and can support it in a balanced way with infrastructure to
match (roads, shops, schools, medical etc). This planning application is, therefore, premature.
- What do the developers mean by affordable? How many single and two bedroom units will be built (given that WC identifies a need for
single units) and exactly how will they be offered? Will local needs be met first?
- The A338 is a busy HGV & commuter route, and additional local vehicles will add pressure on the Borough, High Street and Lode Hill,
up towards the New Forest. Comment on volume of traffic, pinch point, accidents, congestion and fumes. Parking spaces in the
centre of the village and at amenity areas are at a premium. There is no public car park.
- Access to/from the proposed estate is dangerous – being on to a busy road with limited visibility due to bends.
- It is not clear how pedestrian access to the village centre could be facilitated; there is no footpath or natural crossing point.
- Do the schools have capacity for that number of households? In giving up part of the Memorial Gardens, to meet the demands for
previous housing we were assured by Wiltshire Council that there was no need for a new school as there would not be any more
development.
- We have a
Neighbourhood Plan (2017-2026) which was overwhelmingly endorsed by over 90% of those who voted. It accepted an
allocated target of 190 houses (which has already been met), and identified future need as being for managed, sustainable and
small scale development of no more than 25 units in any one scheme.
- The proposed site has high groundwater levels. “Addressing” flood risk for this development simply pushes the problem of
overloaded systems elsewhere. Drains and sewerage on the Persimmon estate (near the Esso garage) still cause problems
despite developer claims at mitigation.
- Environmental issues – how will 100 new houses “benefit wildlife and local amenity” as suggested; what energy efficiency
standards are proposed?
We know there are people in the village who are unconcerned about more housing, and you will, undoubtedly, have comments and opinions
of your own. But do, please, take the time to fill in the survey,
Copy of a letter from Wiltshire County Councillor Richard Clewer to Facebook "Downton Now and Then".
I wanted to give additional information and my thoughts about the consultation from Pegasus Group about Breamore Road and the possibility
of housing there. I apologise if this is a long post but it is a complex issue and I think it will help residents to be fully informed.
Firstly I think it is important to note that this is a consultation that the developer are carrying out, I suspect ahead of putting in a
full planning application. From my experience of these 'consultations' the results are likely to remain private and only be used to try
to support the idea of building on the site. I hope Pegasus prove me wrong and share all the results.
Secondly if a planning application does come forward then it would be a speculative application. In principle the site is outside of
the housing policy boundary (the red line marking where development should and should not be considered in Downton). There are however
two factors which complicate this:
- Firstly Wiltshire Council was found by a planning inspector not to have a full 5 year land supply a
year or so ago. There are two methods by which 5 year land supply (the pipeline of development sites to meet government housing targets
in the local plan) one of which met the land supply but the inspector decided the other method applied. Since then there have been some
successful speculative applications across the county and a major application south of Trowbridge has finally been approved which means
that when the figures are re-calculated this year we are expecting the 5 year land supply to be met. I cannot guarantee that another
planning inspector would move the goal posts again and there is talk of government scrapping the 5 year land supply calculation but I
am as confident as I can be that an application of this type could be fought on a land supply basis.
- Secondly there is a revision of the local plan now being worked on. An initial consultation was carried out earlier this year and there
will be a formal consultation towards the end of the year. As part of this process government now require us (Wiltshire Council) to
assign housing targets (based on the new government targets we have been set) to each large village and service centre. As a result
in the initial consultation it was suggested that Downton could be assigned a further 109 houses between now and 2036. This does
not mean that these houses will be required, my consultation response pointed out that infrastructure (drainage/sewers, schooling parking
capacity etc.) in Downton are under strain and that a period of time is needed to allow the new development to settle in. The Parish
Council made similar points. It is possible that the full consultation later this year will require further housing but it may not and
even if it does then some of this will be delivered through normal planning gain (the development of smaller sites that occurs all the time).
I believe that the consultation and any planning application that comes out of it would be at best extremely premature and I have explained
that to the developers when they presented their ideas to the Parish Council.
If a planning application did come forward then it would need to address the issues of strain on infrastructure, highways access and
perhaps most importantly flooding. It is possible to build on a flood plain providing 'mitigation' was provided. This normally means
expensive works to raise houses or provide flood defences. If that was required the developers would use that cost to argue that less
affordable housing should be provided. There are sites on the edge of Downton that could accommodate housing without building on land
that floods and I would hope planning officers would reject any application to build land susceptible to flooding.
The Neighbourhood Plan is still in place and whilst the provision of strategic sites to meet government housing targets does trump a
neighbourhood plan if more housing is needed, the plan itself should provide protection to the village against more housing outside of
the housing policy boundary. Government have made this more complicated by changing the rules on neighbourhood plans and meaning that
as they run their course they have essentially less effect. The Parish Council are looking at updating the plan (which does not require
more housing sites to be found unless they are wanted/needed) at the moment.
Given the comments on the previous post about the consultation I thought I would also try to provide some clarity about affordable
housing. Affordable housing is defined by government as falling into essentially three types, housing that is sold to a housing
association or the local council and let out at an affordable (80% of market rates) or social (50% of market rates) rent to people
on the housing list, shared ownership which would also be sold to a housing association or the council and then what are described as
'intermediate products' (first time buyer homes, self build and a couple of others). Personally I think that whilst there is a housing
register all affordable homes should be rent or shared ownership. First time buyer provision is also supported by other government s
chemes and should not take up affordable housing provision but should work along side it.
On balance I do not see a strong prospect of any planning application succeeding at this point, that could change if a housing
allocation is assigned to Downton in the local plan update but that will only be determined in about 2 years time after the plan has
been finalised and been through a planning inspection. I think that there are very strong grounds to resist a current application,
particularly on that site but in the final analysis a planning inspector could disagree even if the council refused permission.
In time Downton will be required to take more housing (unless government stops assigning increasingly high targets to rural areas across
England in an attempt to solve the housing crisis in London, Birmingham, Manchester and parts of the South East, an attempt that I think
is misguided and have discussed at length with our MP). I think however there is a very reasonable argument that, given the housing
the village has taken in the last 4 years time should be allowed for the housing and village to settle after their building before more
housing is considered.
I hope this helps give some context, please get in touch if you have any further questions or issues you want to raise.
richard.clewer@wiltshire.gov.uk