here - Downton Parish Council

DOWNTON PARISH COUNCIL
Planning Application Response to
Application 14/06561/FUL - Charles Church - for Land to the West of Salisbury
Road, Downton, Wiltshire - Erect 99 dwellings (83 houses and 16 flats)
together with garages, timber pergolas, garden sheds and refuse/cycle stores
and associated works.
Downton Parish Council is awaiting significant information from Wiltshire Council on
two issues relating to the above planning application in the areas of education
funding and drainage. It therefore wishes to submit a ‘holding’ response only by the
deadline of 7th August. Following resolution of the outstanding issues, it will then
submit a final response once the Parish Council has met to agree it at a meeting on
Monday 8th September 2014.
Downton Parish Council’s comments are as follows under the following headings:
1.
Introduction
Subject to the provision of essential infrastructure improvements and
beneficial community facilities, Downton Parish Council welcomes
development in the context of Wiltshire Council’s emerging South Wiltshire
Core Strategy where, as set out in the latest version of this document, a
maximum of 190 new homes are planned for Downton in the period 2006 to
2026.
Against the 190 target Wiltshire Council have, so far, approved planning
permissions for 73 new homes in Downton of which 58 have already been
built and 13 are currently in the course of construction. Should planning
permission be granted to the Charles Church development this total will
increase to 172 new homes, representing 90% of the plan total for Downton to
2026.
The Parish Council are aware of other landowners / option holders /
developers with ambition to build in Downton (SHLAA site S195 and part of
site S200) and that an Outline Application for some 25 homes on land at
Scotts House, Salisbury Road is imminent. The Parish Council wishes to point
out that, if planning permission is granted to this Charles Church application, it
will look to Wiltshire Council to exercise considerable restraint on any
subsequent planning applications over the next 12 years that would push the
number of additional houses above the 190 limit.
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The Parish Council very much appreciates the positive way in which Charles
Church has engaged with the local community in its various consultations and
welcomes the amendments that it has already made to its plans in response
to feedback received. However, the Parish Council does not recognise or
accept the following summary statements in the Community Consultation
Main Statement:
1.3.5 “... the (consultation) process identified substantial support for the
scheme in the local community....”
6.1.2 “ … Overall, the feedback received is positive towards the
proposed development. ...”
As can be seen from a detailed study of Community Consultation Appendices,
and also the results from the Parish Council's own Public Consultations (copy
enclosed), there is considerable concern in Downton about the negative
impacts to the village and the additional demands that would be placed on
existing overloaded infrastructure. The Parish Council's response to this
planning application closely reflects the key areas of concern.
2.
Drainage, Sewerage System, Groundwater and Surface Water drainage
Downton Parish Council objects to this application on the grounds that
the existing sewerage and drainage infrastructure is already insufficient
to support the current housing and facilities. This is evidenced by the
catalogue of photographs, emails and reports from residents submitted
both to the Parish Council and to the Public Exhibitions in July 2013 and
2014, copies of which are enclosed with this document
Almost every winter in recent times, when the water table is high, the
groundwater gets into the sewerage system, via Wessex Water’s and private
property owners' pipes, and completely overloads the system. This results in
very prolonged periods of
• sewer flooding across roads and pavements and
• unusable toilets and domestic appliances in residents' homes.
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These problems are particularly acute at locations which are near to the
proposed site:
•
The Trafalgar School: From mid-December through to mid-March, up to
four tankers per day, seven days per week, had to come onto the school
site in order to prevent sewage flooding that would otherwise have forced
the school to close. The school also had to deploy temporary toilets for
two weeks to avoid flooding of sewage within the school buildings.
•
Wick Lane: For four months this year untreated sewage, along with toilet
paper etc., fountained continuously out of manholes and ran across the
road in Wick Lane. When vehicles drove through it, any pedestrians
walking by at the time were sprayed with contaminated water.
•
Long Close: Over the same four months, untreated sewage, along with
toilet paper etc., gushed continuously out of a manhole and ran across the
footpath which connects Long Close West and Long Close East. This
footpath is the principal route used by the many parents who live to the
west of the A338 in Downton (Greenacres, Wick Lane, West Wick,
Clearbury View, Mesh Pond and, if planning permission is granted, the
Charles Church development) when taking their young children to and
from Downton Primary School or Downton Community Pre-School in
Gravel Close. As the manhole is on the edge of the footpath, and the
ground slopes downwards from the manhole to the other side of the
footpath, anyone walking along Long Close could not avoid walking
through this contamination and bringing it with them on their shoes into
the pre-school and primary school.
The Parish Council considers it to be imperative that an Infiltration Reduction
Plan is put in place by Wessex Water and asks that Wiltshire Council, as Lead
Local Flood Authority, and as set out in its enclosed letter of 24th June 2014
to Alistair Cunningham, Associate Director Economic Development &
Planning Services at Wiltshire Council, works in partnership with Wessex
Water and the Environment Agency to formulate and implement a
groundwater management strategy for Downton ahead of any planning
consents for new housing developments being granted.
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Downton Parish Council objects to this application on the grounds that
the design of the sewerage system within the site will significantly add
to the already serious problems of Downton's existing sewerage system.
The proposed sewerage system on the site will have at least 200 sealing
joints at which the system will be joined to the dwellings. These will provide
200 additional locations for potential ingress of groundwater into an existing
sewerage that is already completely overwhelmed by groundwater infiltration
in the winter months. To mitigate this problem the Parish Council asks that
Charles Church also be required to install a ‘sealed’ sewerage system within
their site, and through to their connection to main sewer in Wick Lane, so that
no additional ingress of groundwater into Downton’s sewerage system can
ever occur.
Downton Parish Council objects to this application on the grounds that
the design of the drainage system within the site is based on data that
significantly understates the size of the drainage problem.
It is well known, by long term residents in this area, that the proposed
development site is routinely subject to very high groundwater levels.
However, this reality is not reflected in the proposals for addressing the
resulting drainage issues. From the Flood Risk Assessment, it is noted that
the measurements of groundwater levels were taken during a relatively dry
period in 2011/12 compared to the winter months of 2012/13 and 2013/14
when Downton residents observed that groundwater had reached the surface
and was running off the fields to the north of Wick Lane. A further compelling
demonstration of this point is made by comparing the groundwater level
measurements at Woodyates Borehole (the local Environment Agency
borehole just west of Downton). During the monitoring period used for
Charles Church’s Flood Risk Assessment the peak level at Woodyates
Borehole was 83m AOD whereas the level in January this year was 109m
AOD - some 26 metres higher.
It is the contention of the Parish Council that:
•
The groundwater readings obtained by Charles Church's consultants in
2011/12, of between 2.59m and 1.96m, do not provide a realistic base
upon which to design an effective drainage system for the site.
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•
A soakaway system, such as that proposed, which relies on there always
being a minimum depth of 0.7m between ground level and the level of the
groundwater will not work during the types of winter that we have
experienced in recent years.
•
The drainage proposals for the development could make the issue of
flooding worse rather than better in Downton.
•
The pressure of the groundwater on the foul water pipes may cause
groundwater ingress through unsealed joints to add to the current
overloaded system with increased overflowing of drains impacting on
properties and into roads, as has occurred during recent winters.
•
The Flood Risk Assessment does not cover the occasions when
groundwater levels are high and SuDs systems will not work because they
are at or below the water table. This will result in overland flows and
further ingress into unsealed sewer systems leading to further flooding on
site and/or in other locations in Downton.
The Parish Council requests that:
•
The Strategic Flood Risk Assessment, which forms part of the evidence
base for the Wiltshire Core Strategy and the applicant’s Flood Risk
Assessment, is updated to reflect the experience of recent winters.
•
An independent and realistic assessment is made of the groundwater
levels of this site and the impacts on drainage and the sewer system.
•
A workable drainage solution is created, based on the results of the
above, revised data.
•
If soakaways are to form part of the drainage solution that:
•
regular maintenance and clearing of the road surface and the
soakaways is carried out by the maintenance company, and
monitored by Wiltshire Council, in order to prevent the build up of
sediment that would otherwise prevent run off;
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•
3.
the floor levels of the houses are assessed across the site and
mitigation, as necessary, is put in place to prevent groundwater and
surface water flooding of the properties as a result of:
•
groundwater coming up through the floors or
•
surface water running into properties from overflowing drains
when the water table is high and the soakaway system is not
effective.
Education
Downton Parish Council objects to this application on the grounds that
there is currently no agreed solution with Wiltshire Council on:
a) How primary school aged children from the new development can be
accommodated at Downton Primary School without preventing the
exclusion of other potential pupils from the more established parts of
Downton.
b) How pre-school aged children from the new development can be
given access to a Pre-School in the village.
Downton Primary School
Downton Primary School is rated as “Outstanding” by Ofsted. It is a popular
choice for parents in the village and will, no doubt, be one of the key
attractions for potential purchasers of new homes on the Charles Church
development.
From the outset and initial discussions with Charles Church, Downton Parish
Council and the Governors and Management of the primary school have
shared the common aim of continuing to enable all children of primary school
age in the parish to have the option of attending the school.
The new development will inevitably increase the demand for places at the
school. However, as the school is already very nearly at capacity many of the
children from the village will be denied access. Furthermore, as priority for any
unallocated places at the school is based on the distance of the home from
the school, it is the children from the Charles Church development, which is
relatively close to the school, who would be given priority over students from
the more established parts of the village that geographically lie further away
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and who, with their families, have lived significantly longer in the village than
those from the new development. This latter issue will have a significant
impact, every year, on the children who are due to enter the reception class.
The Parish Council regards the above situation, and the very real risk of a
breakdown of social cohesion across the village caused directly by the
building of the Charles Church development, to be completely unacceptable.
Downton Community Pre-School
The Downton Community Pre-School is currently located in the Downton
Band Hall in Gravel Close. This location is not working for the pre-school or
for the Downton Brass Band. Moreover, there is no room to take the additional
pre-school children that will inevitably come from the new Charles Church
homes:
a) There is not enough space inside the hall
b) There is not enough recreational space outside the hall
c) There are not enough toilets
When one factors in the time that is wasted on set up and clear away every
day (to enable the band to use the hall in the evenings) and the other
compromises that are having to be made by both the band and the pre-school
it is clear that the Pre-School needs to be relocated.
The Parish Council has been working hard with Downton Primary School,
Downton Community Pre-School, Wiltshire Council's Education Department
and Charles Church over the last 18 months to ensure that, if planning
permission were to be granted to the Charles Church development, a
workable solution could be implemented that would address the needs of both
the pre-school and primary school aged children of the enlarged village.
A potential solution for both the Primary School and the Pre-School, that
would also provide the village with a beneficial community facility, was agreed
in principle between the various parties last year. This solution was
subsequently displayed at a well-attended Public Consultation, held in July
2013, at which almost 90% of respondents agreed or mostly agreed with the
proposals (a copy of the presentation and the survey results is enclosed).
However, there are some important and essential details which need to be
finalised and which require the urgent and active support of Wiltshire Council
and Charles Church. The Parish Council is therefore objecting to the
application, on educational grounds, until such time as a solution is firmly
agreed.
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4.
Access & Movement in relation to the A338
Downton Parish Council objects to this application on the grounds that
the design of the junction onto the A338 will result in accidents and
further congestion on the A338.
Exit from the Charles Church Site
The Parish Council welcomes the fact that, in the revised plans, there will be
no regular vehicular access via Wick Lane and hence no additional traffic to
and from the Wick Lane junction with the A338. However, the plethora of exits
onto the A338 to the south of the site will make it extremely difficult, if not
impossible, for residents to turn right out of the site at peak times of the day
and evening. Driver impatience will inevitably lead to accidents as well as
further congestion, in both directions, on the A338.
Many residents, based on their own everyday experience of driver behaviour
on this congested road, strongly expressed this point to Charles Church at the
consultations along with their demand that there should be a ‘left turn only’
exit from the site and that traffic needing to exit right should be compelled to
make the short journey to the roundabout to the north.
It is understood, from section 1.9 of the Transport Assessment, that Wiltshire
Council's highway engineer rejected this request with the argument that “it
seems unnecessary and unsustainable to require the additional journey
length” and that “it would also be difficult to enforce and there is no
requirement for the development to be so restrictive in its access
arrangements”. Downton Parish Council wishes to challenge these
arguments as it considers it imperative that, if there is to be an exit onto the
A338 at this point, it has a ‘left turn only’ restriction:
•
the additional journey length to the roundabout and back is minimal –
only 350m;
•
there are precedents for this approach elsewhere in Wiltshire e.g. the
junction of Wilton Road and Netherhampton Road, where vehicles
exiting from Netherhampton Road wishing to turn right are compelled
to make the journey to the Wilton roundabout – a round trip of about
1200m;
•
consideration of safety issues must override sustainability concerns;
through good design of the layout it should be entirely possible to
enforce the left turn – as has been done elsewhere in Wiltshire and at
the Wilton Road / Netherhampton Road junction in particular;
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•
as suggested by Site Layout Plan SL02, there is room for a 'central
lane' (hatched on the plan) on the A338 that could be made an island,
or at least a barrier, to ensure that right turns could not be made from
the site.
To facilitate the creation of a well-designed junction for the Charles Church
site the Parish Council suggests that consideration might be given to either
•
closing off the Batten Road junction, on the opposite side of the road to
the Charles Church site, or
•
restricting the traffic to only a left turn into or out of this end of Batten
Road.
(Ever since the creation of the roundabout for vehicles to gain access to the
industrial estate this end of Batten Road has assumed a much lesser
importance in the traffic flows into and out of the site.)
Puffin Crossing
The Parish Council considers it imperative that the Puffin Crossing beside the
Post Office in the Headlands is constructed before any houses are completed.
However, the heavy volume of traffic through Downton already makes it very
difficult for vehicles to exit from Wick Lane and Long Close onto the A338 and
the Puffin Crossing will make this problem even worse. The Parish Council
therefore requests a yellow box junction between Wick Lane and Long Close
in order to keep stationary traffic out of this space and thereby enable traffic to
exit from these roads.
A338 Traffic Congestion
The Parish Council has serious concerns regarding the high volumes of traffic
on the A338 and the high proportion of A338 traffic which turns into/out of The
Borough (B3080), as evidenced by Charles Church’s Transport Assessment
Appendix B.
At peak times, the traffic light junction of the Headlands with The Borough is
overloaded, as confirmed at section 8.12 of the Transport Assessment. At
peak times in late afternoon it is frequently the case that traffic is queued for
over 2 miles from the traffic lights to Charlton All Saints and beyond towards
Salisbury. The Parish Council is therefore concerned that the proposed
Charles Church development will only add to the congestion inside the 30
mph zone. The addition of a Puffin Crossing to the A338, which the Parish
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Council considers to be an essential element of the Charles Church
proposals, may further contribute to the congestion.
The Parish Council wishes to propose a potential solution to alleviate the
traffic flow issue and to reduce the traffic queuing from the north. This is to for
Wiltshire Council, with financial support from Charles Church, to widen the
A338 at the traffic lights on the junction of The Headlands and The Borough
so that a filter lane can be constructed for traffic from the north to turn left into
The Borough.
5.
Open Space & Landscape
Downton Parish Council has no objection to there being open space provision
comprised of one LEAP and one LAP. It requests that the shortfall in
provision compared to policy be accommodated by an agreed commuted
sum. It also requests that the open space land is transferred to the ownership
of the Parish Council once construction has been completed along with an
agreed commuted sum for maintenance.
6.
Consultants' Reports
As set out in the Planning Noise Assessment, noise from the 3663 Depot and
the A338 is an issue and needs to be mitigated. However, the remedy
proposed is contradicted by the statements made in the Sustainability
Assessment:
•
Planning Noise Assessment p.27 7.3.1
“Due to the need to ensure suitable sound insulation for habitable rooms
exposed to noise from road traffic and the 3663 Depot activities, windows
will need to remain closed even when the desired ventilation rates are
relatively high. Discussions have therefore been had with the client and
the current proposal is to install a system 3 compliant mechanical
ventilation system in all properties need to provide a minimum degree of
façade insulation.”
•
Sustainability Assessment p.6 3.3
“The Applicant is not proposing to install any mechanical cooling …
Openable windows will be a necessary fixture in all dwellings to
encourage natural ventilation. These will help facilitate cross- ventilation,
convective-ventilation and night purging.”
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Downton Parish Council asks for clarification on this point in particular and,
more generally, on which of the many other recommendations and proposals
in the various consultant's reports (Planning Noise Assessment, Sustainability
Assessment, Flood Risk Assessment, Landscape & Visual Assessment
Reports, Transport Assessment, Travel Plan) have been adopted by Charles
Church and therefore form part of its proposals for this planning application
and which have been rejected and so do not form part of its proposals.
7.
Emergency Exit in Wick Lane
Downton Parish Council asks for clarification on whether the size of the
Emergency Entrance and Exit to the site in Wick Lane is sufficient to allow for
the turning and access of emergency vehicles, particularly in view of the
current and potential parking of cars along Wick Lane beside the entrance.
8.
Construction Traffic
Downton Parish Council requests that the following conditions be placed on
any approval notice:
9.
•
further to the Traffic Order concerning the local 7.5 ton zone, as the
Charles Church site is located outside of this zone, construction traffic
is not permitted to use The Borough, other than for access within the
7.5 ton zone;
•
all deliveries to the site are made by A roads only and not via the
B3080 through the village (or through the New Forest) or via Wick
Lane;
•
construction traffic is not permitted to use Wick Lane; on site provision
is made for the parking of all vehicles, plant and materials associated
with the construction.
Design & Access Statement
The map on p.6 of the Design & Access Statement indicates that, in addition
to the shop and petrol station next to the Charles Church site there is,
immediately on the opposite side of the road, a convenience shop. The
Wilton Wholefoods warehouse, which occupies this position on the map, has
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a shop to sell its products but is not really a ‘convenience shop’ as would be
interpreted by the majority of people.
10.
Conclusion
The most recent version of Wiltshire Council’s emerging South Wiltshire Core
Strategy changed the housing target for Downton from “at least 190” to (just)
“190” houses. Downton Parish Council fully supports this change as it regards
it as essential that this maximum limit be imposed. The serious deficiencies in
the infrastructure in the village, as highlighted in this response, along with the
other significant issues identified by residents at the various consultations,
such as the traffic and parking problems in The Borough and the additional
pressures placed on the GP Surgery in the village, which already experiences
high demand for appointments, underpins its position on this point. Although
Downton Parish Council welcomes development in the context of Wiltshire
Council’s emerging South Wiltshire Core Strategy it is unable to support the
current Charles Church planning application whilst the fundamental issues of
essential infrastructure improvements and beneficial community facilities
remain outstanding.
6th August 2014
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