Help save Jefferies Land from Swindon Borough Council

PROPOSED MODIFICATIONS TO THE SWINDON BOROUGH LOCAL PLAN THAT RELATE TO COATE BUILDING PROPOSALS

Apologies if you find this briefing difficult to follow. There is no simple way to explain the situation that currently affects Jefferies Land.

You have until 4.30pm on Wednesday April 5th 2006 to send in any representations to Swindon Borough Council’s Forward Planning, FREEPOST SCE5251, Premier House, Station Road, Swindon SN1 1TZ.

Click

here

to go to the Council's main Local Plan web page if you want to read the documents.

The form to submit your comments should be available at Wat Tyler House and Premier House. You can download the

form

as a small pdf file or you can use the Council's

online service

.

Each representation made in support or in objection requires the use of a separate form. If you cover all the matters raised in this briefing, you need to obtain about 10 forms.

For more information read more or e-mail jefferiesland@tiscali.co.uk

If nothing else, please send in an objection to Modification 45

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Object to Modification No 40

I am one of nearly 30,000 people who signed the Save Coate petition that states: “We, the undersigned, believe that development of the Coate area will have a devastating impact on wildlife at Coate Water nature reserve. It would desecrate an area that has strong historic, literary and recreational attractions and destroy the last remaining pocket of unspoilt countryside close to Swindon. Coate Water Site of Special Scientific Interest contributes to the very best of the rich variety and abundance of wildlife that makes England's nature special and distinct from any other country in the world. We demand that a one kilometre buffer of land is left undeveloped next to Coate Water. We call upon Swindon Borough Council to say NO to development at Coate.”

The number of people who have signed our petition has escalated more than twofold and fourfold respectively since the Local Plan Inquiry and the Wiltshire Structure Plan Examination in Public. The Structure Plan Panel expressed dismay that the public had not been listened to as part of the Structure Plan review whilst the Local Plan Inspector believed that his hands were tied to the Structure Plan decision and the support of Swindon Borough Council over choice of site. This makes a mockery of the development plan process.

I was absolutely clear that the development proposals was not to build on Coate Water Country Park but next to it. However, many people assume that the fields surrounding Coate Water belong to the council and are part of the Country Park; .particularly the Day House Farm field that abuts the northern end of the park. If there was any confusion caused by calling the development area "Coate", this was the reason. To now call the Development Area “Commonhead” causes greater confusion. It is geographically inaccurate. I object to the change of name from Coate to Commonhead – a matter that was NEVER raised as an objection either as part of the Structure or Local Plan process.
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Community Participation is now the buzz word in government. There has been precious little of that in Swindon with regard to the Coate proposals that have been forced upon us. However as the Brighton and Hove City Council versus University of Brighton planning appeal decision indicates, it is never too late for the Council to make amends. If Swindon Borough Council can reject the emerging land-use policy for housing on Martin’s Farm at this late stage in the development plan process when, as far as we are aware, this was not a contentious issue at the emerging Local Plan stage, it has the power to do likewise with regard to the policies that affect Coate. It would be far better to withdraw now than to allow desecration of land that will affect the most popular part of Swindon and its main recreational attraction. Please delete DS3
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I object to changes to criterion [b] that fails to take account of the Inspector’s recommended wording. The Inspector notes in paragraph 5.2 of his report that “Its [the University of Bath] intentions are also to retain its facility at Oakfield”. This statement was echoed at the Wiltshire Structure Plan EIP when the Panel reported in paragraph 5.119 of their report: “We heard from the University of Bath that they are committed to maintaining a presence at the Oakfield site”. As such there is no justification for the LPA to delete the Inspector’s recommendation for policy DS3 at point [b] that states that Oakfield Campus will be retained. This echoes what the University of Bath has said that they want. The Oakfield Campus is now important to the Parks area – local people lost their secondary school with a promise of better-things-to-come by way of the University. Its retention is vital. We ask that the Inspector’s recommended wording for DS3 [b] is retained in full.
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I object to changes to criterion [d]. The planning inspector recommended that 5ha of land should be set aside for hospital expansion. He was informed by the agents for the Swindon & Marlborough NHS Trust that this was all that would be required in the long-term. At the time of the planning application for the hospital at Commonhead, the Trust insisted that the site was large enough to meet their needs – how quickly they were proved wrong despite the public uproar that the hospital would be too small. So why should we now believe the Trust when they say that they will need 5.5ha by 2026? Some hospital expansion would be acceptable given better architecture and height restrictions than currently employed on site. We ask that the Local Planning Authority increases the allocation by 5ha beyond the Inspector’s recommendation to meet the needs of a growing elderly population and a possible town expansion that would add tens of thousands of new houses compared to now.
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I object to proposed modification related to DS3 [i] and request the addition of one word to clarify the Inspector’s use of the word “respect” It is not clear that the policy refers to respecting the rural landscape and open countryside. The Great Western Hospital is now a very visible building from the listed viewpoints identified by the Inspector both within the Country Park and the Downs. Adding the word RURAL after the word RESPECT would clarify that it is the natural rather than the built environment that needs to be respected.
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I object to criterion [j] that does not accord with the Inspector’s recommendation. The policy should include the protection and enhancement of “identified foraging areas” of protected species. The point of Local Plan policy is to identify key areas that should be explored as part of any planning permission consideration. As such foraging areas SHOULD be identified as part of planning policy.

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Object to Modification No 45

Paragraphs 10.2 to 10.10 of the Inspector’s report goes into great detail about the need to protect the rural landscape and he stresses the importance of keeping Coate Water as a “Country Park and not an urban park” [paragraph 10.6].

In addition, the Inspector made it very clear [paragraph 10.7] that tree-planting next to the Country Park’s eastern edge, particularly at the northern end, would not be acceptable in mitigation against development. He stressed the importance of the rural open views from Coate Water that would be blotted out with tree planting.

These recommendations should be reflected in the supporting text of the Plan whilst Appendix 3 requires more description to indicate how rural views will be respected where buildings are allowed.

The lame description proposed by SBC in modified paragraph 1.16.9 - “A number of walks have views and routes across and around the site, the most important of which should be retained.”- falls far short of what is required.

Suggest adding, at the very minimum, the Inspector’s wording [paragraph 10.8] that “ any development should be subservient to the views, retaining the visual link between the Park and its rural surroundings and maintaining its rural character… strategic planting does not provide a solution”.

With reference to the width of buffer proposed by English Nature, to protect and enhance Coate Water Site of Special Scientific Interest, the figures quoted by English Nature, to which the Inspector refers, were their MINIMUM required. Originally English Nature requested a PRECAUTIONARY buffer of 500m at which point they were told to look again by the developers! As such the word “precautionary” should be replaced with MINIMUM in the sentence that reads: English Nature favour a precautionary buffer zone of between 100 and 200 metres in width” etc. whilst the text might refer to English Nature’s 500m precautionary buffer. Ask that the words “250m wide” is added before the “D-shaped field” to clarify English Nature’s minimum requirement for this field.

It needs repeating that we believe that the buffer around Coate Water should be up to 1km wide in order to protect the literary, landscape, historic, cultural and ecological qualities of the area and we shall continue to say this until we are blue in the face.

Finally for this section, point out that SBC has failed to take on board the Inspector’s recommendation related to the buffer set out in paragraph 10.18 of his report.

The Inspector says that “Appendix 3 should be expanded to indicate that the buffer to be established before development commences and how it will be protected and managed”. The Borough Council has only talked about the size of buffer that might be required and not the management of it.

Say that the Inspector’s requirement MUST be laid out in Appendix 3. Say that a statement should make clear that development may have to be delayed for several years in order to allow buffer planting and enhancement of the habitat to be established before any building work commences in order to benefit protected species. Say that a condition of development should require any buffer land to be given over to the Jefferies Land Conservation Trust as part of the management process.

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Object to Modification 42

This section is related to the phasing in of any proposed town centre University of Bath [UoB] faculty. Unfortunately the Inspector has agreed with SBC that the UoB should not have to phase in the Arts faculty [or any other town centre stand-alone faculty] to tie in with the development of the Coate campus. This is staggering given the importance attached to the presence of a town centre faculty as part of the Urban Regeneration scheme that has been recognised by the Inspector and the Borough Council as vital. Originally it was proposed that the central faculty should be built before Coate but the developers lobbied to get this criterion deleted. The Borough Council has now couched the policy in terms that the town centre faculty should be “phased for completion by the time the campus at Commonhead is fully developed”. This leaves the question of the Central faculty in the air and in doubt as the Coate campus may never be “fully developed”. The plan to accommodate 10,000 students at the Campus is a long term goal for the UoB. The Planning Inspector suggested that a time delivery for the central faculty should be set as a condition to any planning permission granted for the campus. 5 years is often the period set in planning conditions for things to happen. Suggest that this criterion, [ie a condition to build a central faculty or faculties within a given time frame, say 5 years, of granting planning permission for the Coate campus], should be added to Appendix 3. Say that the words “fully developed” give too much lea-way given SBC’s commitment to the urban regeneration scheme and the importance of the central faculty.

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Object to Modification 54 on grounds of omission of Inspector’s comment in paragraph 10.18

The Inspector said “that further consideration be given to whether any additional facility beyond the performing arts centre should be located within the town centre without undermining the benefits of focussing activity on the main campus”. SBC has opted to pursue this recommendation with the UoB outside of the Local Plan process. This isn’t good enough. There should be a statement in the Local Plan that refers to an active commitment to look for other University stand-alone facilities in the town centre in the light of the importance of higher education as part of the town centre regeneration scheme and as set down in Regional Planning Guidance for the south west.

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Objection on grounds of omission to Coate development. Inspector’s ref: paragraph 10.11

There is no mention whatsoever of Richard Jefferies and the importance of the area to him in the emerging local plan apart from using the word “cultural interests” in proposed modification 45 that can be supported. Even the Inspector mentioned Richard Jefferies albeit that he said that Jefferies was no Wordsworth or Hardy. However this is a matter of opinion and open to challenge. His view is not based on any evidence. The importance of Jefferies' literary landscape at Coate has been flagged up yet again recently [Spring 2006] in another national magazine,

This England

. A recent article by Simon Barnes, that appeared in the Times on 7 January 2006 also echoed the same sentiments that Jefferies literary landscape must be protected because of his importance as a topographical writer. It would appear that everyone appreciates Jefferies apart from planners and Swindon Borough Council.

Say that you want the Local Plan Inquiry to be re-opened to look at the impact of development on what is left of Jefferies Land that has already suffered as a result of creeping development of Coate farm. Say that the Jefferies' importance has not been investigated by Swindon Borough Council or the developers interested in the site and that the land has not been subject to the same degree of scrutiny as other potential constraints.

Ask that Appendix 3 should list a criteria that any Environmental Impact Assessment should study the impact of development on the literary quality of the landscape with reference to Richard Jefferies and how any adverse affects might be mitigated. State that no study to this effect has been conducted by the Borough Council or the developers and that, in view of the international importance of this writer, this is a serious failing of the entire Local Plan policy related to the Coate development.

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Objection to modification 51; Urban Inset map that identifies 3 new areas for development along Day House Lane.

The changes proposed to add three hatched areas for inclusion under policy DS3 are said to be the result of the Inspector’s recommendation to support PANs 467, 468 and 469. As these Borough Council changes were never subject to public consultation or made known to the general public, I have no idea what was proposed but object to the changes now. The areas that would be included under the Coate development policy cover listed buildings [the out-buildings] at Day House Farm and at Badbury Wick. It includes Medieval settlement land at Badbury Wick that should be covered by ENV5 but isn’t. Finally it includes the Scheduled Ancient Monument of the Neolithic Stone Circle that IS protected by ENV5! . These areas are not subject to negotiation and cannot be developed regardless of whether the house-builders now own the land. These areas need to be excluded from policy DS3 to protect their archaeological, architectural and historic importance.
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And as a postscript, given again that we are totally opposed to all this, it is difficult to support any of the proposed modifications related to Coate even though, if the development goes ahead, the modifications may need supporting in their own right.

So if you can grit your teeth, you might support the following. You don’t have to give a reason for supporting the modification.

Modification 44 ties in any employment use of land to be linked to the university. The developers don’t like this modification so they will object.

Modification 45 supports protecting environmental interests of the land and buffers and “historic and cultural interests at various locations within the site.” This can be looked at as an opportunity to flag up Jefferies’ interests.

Modification 46 supports the need for a thorough Environmental Impact Assessment of the proposals and the provision of green corridors etc.

Modification 50 supports buffer zones of at least 30m for County Wildlife Sites and at least 10m to water courses. The County Wildlife Sites are Day House Copse and Burderop Wood North. There is also the Nature reserve at Coate Water but this will be subject to its own wider buffer requirement.

Modification 52 supports the removal of a field of archaeological importance from development land at Badbury Wick.