Objections to the emerging MANP

Preshute Parish Council
25 January 2020

Introduction
Preshute Parish Council object to the emerging MANP. In particular, we object to the adverse effects further large scale housing development will have on the North Wessex Downs Area of Outstanding Natural Beauty (AONB). Preshute parish is entirely within the AONB and is an attractive downland community that frames the setting for Marlborough - arguably the most attractive market town in Wiltshire and the most important Kennet Valley settlement.
Preshute PC is of the opinion that little regard has been paid to the landscape quality, tranquillity and the visual setting of the town or the rural character of the area. The impact of large scale incursions into the unspoiled AONB will also have an adverse effect on the setting and approach to World Heritage sites in the neighbourhood.
In objecting to the suggested large scale development into protected landscapes (contrary to national guidance and adopted strategic policies), it is also clear that there is no justification for the proposed large scale development in Marlborough at all.
Preshute PC is of the opinion that the emerging MANP housing policy is flawed and unsustainable for the following reasons:
Reviewing the MANP proposals in general, it is notable also that there are no air quality or other defined environmental goals or a quantifiable objective for new jobs. There is no evidential justification of the need for a new medical centre or how the large population growth in the current period will integrate smoothly into community amenities or services. These should be clear goals if the Plan is to have any value.
This paper questions the unjustified NPSG proposals for housing beyond 2026. We request a review of the emerging plan and in particular its calls for the prioritisation of nationally protected landscape in preference to suitable, available and deliverable brownfield land within the Marlborough Settlement Boundary (SB). There needs to be a review of the sustainability goals of minimising car travel, congestion and improving air quality by phasing car parking, new public services and new employment with any new housing.

The housing need 2006-2026
The assessed housing requirement (Wiltshire Core Strategy (WCS) as approved by the Secretary of State) for the East Wiltshire Housing Market Area (EWHMA) is 5940.
Defining the housing need 2026-2036
Wiltshire is now preparing a review of the WCS to take it forward to 2036. This will be called the Local Plan. Since the WCS was adopted in 2015, the relevant Housing and Economic Market Area for East Wiltshire has been significantly increased with the addition of Swindon. As a result, there is no agreement yet on the amount of new housing in the new Market Area, and in particular how much of that should be directed to the towns in that area (Swindon, Devizes, Calne, Royal Wootton Bassett and Marlborough). The apportionment will take into consideration environmental constraints and opportunities, land availability, sustainability, accessibility to public transport, etc.
Sequential testing for site selection
Site allocation for new development should follow a sequential procedure that chooses the most sustainable, available sites first through to those that are less sustainable.
Applying the national guidance (NPPF, the National Planning Policy Framework), priority must be given to previously developed land, followed by unused or underused land within the existing SB and finally, if necessary, suitable greenfield extensions.  
Applying the sequential test to the identified, known available and previously developed sites within the Marlborough SB produces the following list:
•    Previously developed (redacted for privacy reasons here)
•    Unused available
The above sites have a capacity of around 200 dwellings. The above doesn't take into account additional windfall sites
•    Greenfield sites
The reality would be that it is very unlikely that large greenfield sites would be required.

Conclusions
The NPSG Pre Submission Proposal on Housing does not stand up to detail review and is at best premature ahead of the Revised Local Plan from Wiltshire Council. At this stage, there is no strategic basis for any additional housing beyond 2026.
Instead of a considered approach given above, the NPSG housing proposal for 250 new dwellings is based on an out of date and flawed opinion poll for a small part (Marlborough) of the previous HMA. The site selection process has not been sequential or objectively assessed for landscape impact. The largest development site is at Barton Dene, which encroaches significantly into greenfield AONB and Preshute Parish. (the SEA, by consultants Aecom, appears to have been ignored, see footnote below).
Improved medical facilities are indeed required within the Marlborough area, but the need for these should be properly assessed by the relevant clinical commissioning body, funding allocated and phased. The provision of such facilities should then be explored by that body in a systematic way, including examining the expansion of the existing surgery into its own car park (as there is a large public car park within 50metres). The planning and provision of primary care is a complex process and not simply a case of putting a symbol on a greenfield site.

For these reasons, Preshute PC object to the emerging MANP. We suggest a proper methodical approach applying National and Strategic guidance and implementing the strategic requirements for the period after 2026 once this has been finally approved. The current plan is premature as it stands since there is no strategic policy or evidence to support the Plan.

Footnote
The AECOM SEA report on the issues at Barton Dene states: "Development at the site would also likely set a precedent for further growth into the open AONB landscape, with the potential long term negative effects on character and the special qualities of the AONB, including setting and views." It also states: "that this parcel of land is an informal community asset. Development would result in a loss of area of informal open space and extend into open countryside. The assessment concludes that the development would be detrimental to the special qualities and natural beauty of the AONB and the site should not be taken forward as part of the SHLAA (The WC Strategic Housing Land Availability Assessment)." In short, this land has already been rejected.

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