What Else is Wrong with the Plan?

Objections to the revised deposit draft Local Plan must be submitted to Swindon Borough Council by 4.30pm on Monday 12 January 2004. No late submissions will be accepted. You can view the document at Wat Tyler House, Premier House or at all borough libraries. You can only object or support the proposed changes.

The address to submit objections is:

Forward Planning Group, Freepost SCE5251 Swindon Borough Council, Environment and Property, Premier House, Station Road, Swindon SN1 1TZ.

There is a dedicated form that can be sent for each objection raised. Some objections will need to be repeated as they appear under several policy changes.

Download objection form now

Objection 1

Plan policy ENV16

Biodiversity: National Sites

There is no justification to change the draft Policy. It is weakened by taking key considerations out of the main text of the policy and placing the wording in the sub-text. It is evident that there are so few internationally designated wildlife sites in the UK that more National Nature Reserves and Sites of Special Scientific Interest will follow international designation. As such, they should be afforded equal weight in planning policy.

Support policy ENV18

Support changes to Habitat and Species protection - the Local Plan changes proposed ensure that species as well as habitats are afforded extra protection - this change in policy is welcome.

Objection 2

Policy E6

Mixed use development at Pipers Way and Groundwell

The full 6 ha of employment land at Groundwell and 5ha at Pipers Way should be retained solely for employment use and be retained under policy E1 as key employment sites that serve growing local communities. It is inappropriate to change the use of these sites for proposed hotels that should be located in the town centre, and, given the proximity of the land to new residential areas in the NDA and SDA, class B use would be more suitable.

Objection 3

Policy H4

Residential Development - Phasing and Monitoring

Delete text from the policy that states "it is clear that phases shall not deliver the rate of completions required to maintain a five year supply" and all supporting text in justification of the phrase.

It is not proven that the phases laid down for development will not provide a 5 year supply of land for housing. Monitoring shows that an average of 800 new dwellings have been completed each year for the last six years. The indicative figure in the Structure Plan is that 1,467 new dwellings should be built each year to reach the Swindon allocation. The Northern Development Area [NDA] has planning permission for a further 5,000+ houses. Urban sites provide for another 2,300 dwellings. This provides a five year supply of land given the "target" building rate and a nine year supply using the current building rate.

Objection 4

Policy H10

Provision of affordable housing in larger development sites

The 2001 Housing Needs survey has identified that there is an annual shortfall of 1,218 affordable dwellings a year. In July 2003, there were 5,715 people on Swindon’s council house waiting list - 400 of these were homeless. The situation is critical and getting worse. The shortfall suggests that Swindon’s new dwelling provision should all be for affordable homes.

Object that the criteria, for assessing the component of affordable housing sought on sites, has been increased from clusters of 15 to 25 or more dwellings and on sites of 1 hectare rather than 0.5ha. If there was no demand for affordable housing in Swindon than the new criteria might be acceptable. However, the situation is critical - those that are really in need of a new home should be given priority. The original quantum should be retained in the policy.

Object that the starting assumption that 30% of houses should be affordable has been deleted from policy H10 and replaced with the wording that "a level of provision appropriate to the site, taking into account information provided by the latest housing needs survey, market conditions etc." Whilst the planning authority would still seek 30% provision on suitable sites, albeit that this figure is too low to meet current needs, without a policy commitment, developers will seek to wriggle out of any obligation. As a land-owner, Swindon Borough Council has now lost its last major plot of land (that is the SDA) where it can implement the 30% affordable home provision more easily. It is to be welcomed that the SDA planning application provides for the building of about 1,350 affordable homes even though the indication is that a far higher quantum of council houses is needed.

It will be even more difficult to secure affordable housing provision on privately owned land unless developers are fully aware that they are obliged to meet the need for affordable homes. Whilst the policy now seeks to secure commuted payments in order to build affordable houses elsewhere if the developer does not provide sufficient affordable houses on their plot, there is no indication how much the commuted payment might be and whether it will secure the housing needs survey requirements. The Supplementary Planning Guidance [paras 5.6-5.7] admits that the housing need survey of 2001 suggests that the need for affordable homes is greater than the 30% figure suggested in the Plan. The 30% affordable target should be a minimum not a maximum.

The policy also includes a target to provide 50 low-cost dwellings a year for the open market.

Objection 5

Policy H12

Prestigious Low Density housing

Object to this new policy to deal with the provision of prestigious housing to encourage heads of business and industry to live in the Borough. This is a licence for developers to break all the rules! The policy applies to buildings of exceptional quality but it allows them to be built at sites that would not normally be allowed. This exceptions policy is not acceptable.

Objection 6

Policy CF12

Wind Turbine Development

The policy for wind turbine development has been altered to make it more difficult for wind turbines to be approved if major proposals "adversely affect views from" Areas of Outstanding Natural Beauty. This is clearly ludicrous! The addition of this text to the policy has no grounds for inclusion and should be removed.

The Government's aim is to put the UK on a path to cut its carbon dioxide emissions by some 60% by 2050, with real progress by 2020. Action is desperately needed now to reach these targets as the effects of climate change are now starting to bite.

The Government is consulting on a new Planning Policy Statement (PPS22) for renewable energy. Up until now, planning authorities have afforded little weight to the wider environmental and economic benefits of proposals for renewable energy projects. The Government is seeking to reverse this. The Government do not rule out small-scale development of wind turbines in Areas of Outstanding Natural Beauty and they now advocate that planning authorities should not designate no-go buffer areas next to AONBs for the provision of wind turbines. They also advise that rural buffer designations should not be used in themselves to refuse planning permission for renewable energy developments.

As such, not only are the changes proposed to policy CF12 unacceptable, the policy may have to be relaxed to allow wind turbine applications to be assessed in a more favourable light.

For more information contact:
Jean Saunders
Swindon Friends of the Earth
Foeswindon@hotmail.com
Tel: 01793 783040