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Chair: Paul Exell (email: phone: 01793 703276)

Membership Secretary: Sarah McDermott

ORA Core Strategy Response

Comments on the “Soundness” of the Draft Core Strategy and Development Management Policies
1.      Background – Oakhurst Residents’ Association (ORA) was formed in 2005 and is fully constituted and recognised by Swindon Borough Council (SBC).  Oakhurst is a distinct and discrete area of North Swindon entirely constructed from 2000 onwards.  The members of ORA are drawn almost exclusively from the Oakhurst area and out of the 1,370 dwellings in the area over 500 households are currently signed up as members.  In addition, there are associate members who live in Redhouse, Blunsdon St Andrew and St Andrew’s Ridge.  ORA have held two public meetings in the last few months and over 120 members attended each time to discuss their concerns with the local MP, senior councillors, ward councillors and senior officers about the inclusion of Tadpole Farm in the Core Strategy. This submission is fully representative of the views of our membership.

2.      The Draft Localism Bill – There has been massive local opposition to Tadpole Farm’s inclusion in the Core Strategy – the MP is against it and the ward councillors have already stated their opposition to the proposed development. This is due to the lack of deliverability of the necessary infrastructure to mitigate the effects of any future development on existing local communities. This opposition has been voiced at the local ‘Connecting People, Connecting Places forum.  A resolution was passed by Blunsdon Parish Council, Haydon Wick Parish Council and two Residents’ Associations (ORA and Rodbourne Cheney Residents’ Associations) that, “there should not be any further development in North Swindon unless the appropriate, promised and future infrastructure is put in place – roads, community facilities and schools”.  This view has been supported by the North Swindon MP and local councillors in public meetings to discuss the Core Strategy.  The Leader of Swindon Borough Council has made it clear at a Full Council meeting that, “the councillors do not have to take the communities’ view into account” in this matter.

The draft Localism Bill encourages “devolving power closer to neighbourhoods...putting communities in charge of local people and communities far more ability to determine the shape of the places in which they live...” and Local Planning Authorities (LPA’s) (being) able to begin working in new ways on local plans in advance of the passing of the Localism Bill”.  Swindon Borough Council do not appear to have taken the community view into account and acted upon it in any discernable way, as yet, despite all of the arguments being based on material planning grounds.

3.      Management Summary: ORA have looked at the whole core strategy and used the major categories for reference.  However, our submission is based in the main on Policy NC5 – Tadpole Farm pgs. 106 - 108.  Our main points of concern are:
a.   Employment: The provision of employment opportunity in the Northern Development Area (NDA) and proposed Tadpole Farm development is poor.  These developments are geographically positioned at the furthest point away from the centre of Swindon compared to other development areas. They are also not within easy commutable distance of the eastern employment areas which will inevitably undermine attempts to provide a good range of travel choices identified in CT2 of the Core Strategy pgs. 29 -30.
b.   Waste: As it stands the Core Strategy does not address key strategic issues with the wastewater network. These issues are particularly acute for any development to the North and North West of the town with the current sewer network already at full capacity and solutions, which will be expensive and difficult to implement, yet to be defined or funded.
c.      Traffic: The road infrastructure in North Swindon is not sustainable, with no direct route into either the town centre or employment areas.  Any further development will further stretch the capacity and lead to concerns over safety and the impact on the quality of life of existing communities contrary to Policy NC5 D, “Development at Tadpole Farm will integrate with the existing communities in the North Locality cluster and maximise the opportunities for the nearby residents to benefit through safe, attractive and direct links to new facilities and improved public transport links”. The further development of this area will have an adverse impact on communities along which traffic will be forced to flow, including Oakhurst Way, Garsington Drive, Salzgitter Drive, Tadpole Lane, Thamesdown Drive, Akers Way, Cheney Manor Road and the routes through West Swindon (Mead Way/Whitehill Way) to M4 Junction 16.
d.      Education: The NDA has grown over recent years without adequate local provision for education, and is still continuing to grow with many existing development sites not yet completed.  It is already, frequently not possible for parents to get their children into their local school – resulting in a need to travel to a school further away.   Further development at the Tadpole Farm site will exacerbate this issue, with inadequate school places being provided for the residents and, in all likelihood, the school provision being delivered well after occupancy of the residential build has started placing further burdens on the existing schools of North Swindon.  Secondary provision is under particular strain in this area.
e.     Green Infrastructure: The River Ray and associated green corridor is not directly accessible to residents.  In the North and West of the development (Oakhurst) access to green infrastructure is prevented by the railway line that runs from Purton Stoke to Mouldon Hill. It will be necessary to provide new crossings over the railway and River Ray. It is not clear how the funding is to be secured for the development of the Cricklade Country Way or associated access from the NDA.
f.       Brownfield Land: The Core Strategy does not place enough emphasis on the development of brownfield sites.  Just 17% of the development proposed will be using brownfield land despite so much of this land being close to the Town Centre which is at the heart of SBC’s Core Strategy objectives (see SC1 Pgs. 62 -63). 
g.   Sustainability: ORA’s assessment of the Core Strategy supports the previous evidence base of the Swindon Joint Study 2026, Interim Report, May 2005 (Joint Study) used to inform the old Regional Spatial Strategy. This concluded that development to the North and North West of Swindon represents one of the least sustainable sites for development compared to other areas, such as to the east of Swindon, and this has far-reaching effects on the permeability of the site. Consequently it will require far higher investment in infrastructure than other potential development areas, and this is unlikely to be deliverable in the current economic climate or from developer S.106 contributions.
h.   Flood Risk: Flooding is a very serious concern for residents of Oakhurst that live near or adjacent to the river Ray and Tadpole Lane.  In recent years the River Ray has burst its banks several times. Most notable of these occasions was in 2007 when flood waters engulfed Tadpole Lane and the surrounding fields to a depth of several feet.  On that occasion the waters extended significantly beyond the current Environment Agency flood maps. Several homes suffered flood damage and Tadpole Lane was impassable to smaller vehicles for several hours.  In the Wiltshire Council Special Planning Consultation many residents submitted their concerns regarding the flooding of the River Ray in the Tadpole lane area.  These concerns are still displayed on the Wiltshire Council consultation portal.  ORA do not feel confident that promised work on the watercourses has been carried out or that the causes of the flooding have been properly identified and mitigation planned.

4.      Main Concerns
a.     Employment
SBC have always supported the idea that jobs should be close to new development sites and employment has always been the central tenet of previous Core Strategies (and the current Core Strategy).  Policy CT2 G. Pg. 30 states that, “Economic and housing growth should benefit existing and new communities through safe, attractive and direct links to new facilities, improved access to transport and new jobs....”.   This is how, “all Swindon people are benefitting from our growing economy” (Policy CT2 pg. 29).
The NDA has grown over recent years without adequate provision for local employment.  With the possible exception of the Northern Orbital Retail Park on Thamesdown Drive there is little ‘delivered’ opportunity for employment for local residents within easy access of public transport or walking/cycling (public transport has been focussed on routes to the town centre but not connecting outer areas).
The proposed development at Tadpole Farm is likely to make this situation significantly worse.  The suggested allocation of 5 hectares (NC5 A. pg. 106) is unlikely to provide sufficient jobs for existing and new residents assuming the new development will contain 1,700 new dwellings (and the overall housing target for the NDA is 3,970 houses).

·         The Swindon Workspace Strategy and Delivery Plan states, “the preferred option for the Eastern Development Area (EDA) seeks to provide a range of employment types and uses creating approximately 5,000 jobs, in accessible locations”. [sic]

In comparison, at Tadpole Farm it was proposed to provide an area of employment land to provide about 500 jobs (about 10ha), with the expectation that these will be relatively small scale.  In fact the current Core Strategy only allocates 5ha for employment land (B Class uses pg. 106) with an assumed corresponding reduction to around 250 jobs in a less accessible location.  This number of local jobs located in a development of 1,700 homes adjacent to the existing NDA means that the vast majority of residents will be required to commute to an alternative employment area.

The “Good Quality Employment Site” shown at Fig. 16 – North Swindon Communities Inset Diagram, pg. 31, fails to indicate that quite a lot of the employment land remains undeveloped (for many years) and there is no reference to the approved development at the Abbey Stadium on Lady Lane (which will eventually lead to a high density 450 house development where a compromise to rebuild the Abbey Stadium led to a reduction in the employment capacity of the land).  There is no public transport link between Tadpole Farm and these sites (Abbey Stadium and Groundwell West).

·         The travel distance to alternative employment areas will increase the number of vehicle journeys.  According to the Joint Study point 17.44 there is a “significant lack of jobs within walking distance and even cycling most jobs are at the threshold of the distance” and point 17.45, “Consequently the overall (employment) assessment is fair”. [sic]

·         The Core Strategy Policy CT2 point 3.11 (pg. 32) predicts “strong potential for growth in car manufacturing clustered around East Swindon, associated with existing employers and transport links”.

·         The document Core Strategy & Development Management Policies - Revised Proposed Submission Document; Sustainability Appraisal incorporating Strategic Environmental Assessment; Policy SC9  states; “Improving public transport links, walking and cycling network will encourage sustainable modes of transport”.
Even assuming funding could be found for these improvements, Tadpole Farm is geographically located at the furthest point from the town centre and a minimum of 6 miles from the Eastern employment area which includes the major areas of employment land identified in the Economic Growth Diagram, Fig.4, pg. 31 and Policy CT2 (pgs. 29 –36).

·         Residents of the NDA and proposed Tadpole Farm that take up employment in these areas are unlikely to have the option to walk or cycle. There is also poor provision of public transport from Tadpole Farm to the Eastern employment areas. Therefore sustainable modes of transport are unlikely to be adopted.

·         On Pg. 18, of the Core Strategy; The Spatial Vision states that, “Swindon will become one of the best business locations in the UK, offering a high quality of life, not just to its residents, but also to those from a much wider catchment area. New jobs will be created and there will be the fullest range of employment opportunities for the whole community”.  It appears that the residents of the NDA and the proposed Tadpole Farm development will find it necessary to continue to drive to work.

·         In Appendix 7; Glossary of Terms, the term “Travel to Work Areas” is defined.  It states that, “for those involved in labour market analysis and planning, it is useful to be able to use data for zones that are labour market areas. To meet this need, the zones are defined so that the bulk of their resident population also work within the same area. Defining labour market areas requires the analysis of commuting patterns”.  There is no mention of the analysis of commuting patterns within the core themes of the Core Strategy and the evidence base does not reflect that this analysis has been carried out or reflected in the Core Strategy. The relationship between new housing and new or existing employment areas is unclear.

·         Policy CT2 point 3.16 states, “but where the town centre would not be suitable, development must not harm town centre regeneration and must be accessible with a good range of travel choices”.  It seems likely to prove very difficult for residents of the NDA and Tadpole Farm to benefit from a “good range of travel choices” which will significantly restrict employment opportunities for residents that do not drive.

·         Joint Study, Figure 7.1 indicates that the area around the River Ray, which includes the Tadpole Farm site, is rated poor for employment accessibility.  

b.     Waste – Waste water treatment and sewer network capacity
Policy CT3 of the Core Strategy states in Part C “that future water supply and wastewater will be addressed by:..river-water quality improvements”.
As described in the Swindon Water Cycle Study (March 2007), Swindon Sewage Treatment Works (STW) currently discharges to the River Ray. The River Ray is a small watercourse and has little dilutive capacity. The effluent consent standards are therefore stringent, requiring the STW process to treat to the highest standard achievable with conventional technologies. Concerns have previously been raised therefore by both Thames Water Utilities Ltd (TWUL) and the Environment Agency about the capacity for growth within Swindon. There is some capacity in the existing flow consent for a limited amount of additional population, but once the consented flows are reached, any growth will require more stringent treatment than conventionally applied, or may result in a deterioration of river quality in the River Ray, and potential failures of statutory water quality targets. To meet the growth requirements of Swindon a second STW is therefore required.
Policy CT2, Theme 3, Point 3.41 (pg. 37) of the Core Strategy describes the need to expand Rodbourne STW and the need for an additional STW to serve the Eastern Development, but ignores the issues of treatment capability for other growth areas.
Evidence provided by TWUL indicates that the sewer network that serves the North of Swindon is full to capacity. So much so that Thames Water have told SBC that no homes in any proposed development area to the north of the town (including Tadpole Farm) can be occupied until the necessary infrastructure has been provided. Without this infrastructure the probability of foul water flooding, with the associated distress of homes being flooded with sewage and the accompanying health risks are unacceptably high.
The Swindon Water Cycle Study (March 2007) states that network upgrade is “expensive and disruptive”, and sufficient lead times need to be given to allow the necessary infrastructure to be provided.  It is noted in the Joint Study Supplemental Information, paragraph 6.41 that “Planning for future water resource and wastewater disposal infrastructure is hampered by short term funding arrangements and uncertainty over consenting and abstraction requirements. These matters, along with inter-regional co-operation over water supply/disposal, are issues that require urgent attention at a regional level.”   It is also noted in the Joint Study, paragraph 17.44 “A new sewage treatment works would be required north of Swindon”.
ORA understand that TWUL is currently designing and costing options to address the current deficit in network capacity servicing North Swindon. However, any solutions will be expensive, and approximately 50% of the cost will need to be met by the developers (as defined by Ofwat in their PR09 Final Determination). 

It is also clear that for any optimal solution to be developed, TWUL will need to take appropriate judgements on the additional growth in the neighbouring development areas proposed by North Wiltshire District Council (NWDC) now Wiltshire Council. This demonstrates the need for SBC and NWDC to work collectively in providing TWUL with a robust long term forecast of the future growth in this area such that the necessary sewer and sewage treatment infrastructure can be provided. 
The need to address the acute issues of the wastewater network therefore needs to be incorporated into “Policy NC5 – Tadpole Farm” of the Core Strategy.
c.      Traffic
Core Strategy Policy SC7 B (pg. 81) states that it is a local priority and aspiration to “address issues around traffic travelling from North Swindon to Swindon town centre”, yet the Local Transport Plan 2011 (LTP) cannot be implemented due to financial constraints. In the Joint Study Supplementary Information (Sept. 2005) paragraph 6.41 it states thata realistic but challenging transport strategy has been outlined to support future growth at Swindon” but it then goes on to state that “an assessment of funding sources shows a large deficit exists in funding for the proposed strategy.  Additional financial support on a significant scale will be required from Government Funding or currently unknown sources if the transport strategy is to be realised”.  The LTP also states that “there are currently too many uncertainties on funding to be able to come up with implementation plans”.

ORA note that the Joint Study point 17.42 states for the River Ray development area (which encompasses Tadpole Farm) that, “The area is limited by the low capacity highway network that places significant traffic pressure on existing roads.  The area could tie into the Northern Orbital Road and the Purton-Iffley Link, although the former would require costly upgrading of the existing route and the latter could result in significant loading of the road through Blunsdon village”.

The Core Strategy does not present any viable solutions to the traffic problems.  Indeed this document contradicts itself.  Fig. 16 pg. 80 North Swindon Communities Inset Diagram has Tadpole Lane as a Secondary Road transport route, yet Fig. 24, pg. 107, Tadpole Farm Inset Diagram, shows two primary access roads, one through Oakhurst Way and the other to the North East through Blunsdon.

The introduction of a Rapid Transport Route/Rapid Transit Link (RTR/RTL) - Policy NC5 B “a rapid transit link between Tadpole Farm and Swindon town centre from the first phase of development and other public transport links” is also not viable.  The Implementation and Monitoring Plan (March 2011) gives the timescales of 2011-2013 ahead of even Wichelstowe.  ORA ask how this can be delivered in isolation and ahead of the rest of the network?  In the previous Core Strategy consultation, Respondent Reference 96 supported the “provision of public transport links from the first phase of the Tadpole Farm development.  The introduction of a rapid bus route from Tadpole Farm to the town centre is a key component of the sustainable transportation strategy for the site”.  On pg. 108 point 4.77 the Core Strategy states, “a rapid transit route is critical to deliver the smaller scale urban extensions in a sustainable manner and should be phased in the early part of the development”. In recent discussions between Respondent Reference 96 and the local communities, the Respondent has already conceded that there is unlikely to be a RTR/RTL because it is not viable.  This is largely due to the fact that the RTR/RTL will have to share the existing road network which is not suitable for the creation of bus lanes.   The travel time for reaching the Town Centre is currently 40 minutes by bus and, without the investment in bus lanes, it will be difficult to achieve any improvement to this time.  The Strategic Highways Officer for the Core Strategy has already confirmed, at ORA’s Committee meeting about the proposed document with senior SBC officers, that “no bus lanes will be constructed”.  The route indicated at Fig.24 pg. 107 is not identified clearly – there is no mention of any road name in the text but in Fig. 16, pg. 80, North Swindon Communities Inset Diagram, there is a suggestion that the RTL will be down the side of Isambard Secondary School.

It has been difficult to achieve sustainable funding for the current bus services in Oakhurst and the surrounding areas and since the S.106 money supplementing the services has finished some bus routes have been reduced.  Services 15 and 15A are currently being reviewed.  As of the 5th June 2011 the local bus operator (Thamesdown) will only be providing services from Monday – Saturdays and the 11 service does not run after 20.45 and the 19 will no longer serve Taw Hill, Oakhurst, Redhouse and Haydon Wick.

There are also strong grounds for concern that the traffic modelling for Tadpole Farm is being carried out in isolation, i.e. it is not taking into account all of the other proposed developments to the North West of Swindon (e.g. plans are currently being determined by Wiltshire Council for 800 houses at Ridgeway Farm and approved sites of 450 houses at the Abbey Stadium, 200 houses at Moredon Bridge, 290 houses at Hreod North – the Core Strategy figure for the NDA being an additional 3,970 houses, which does not include any additional development on the Wiltshire side of the Western border apart from Moredon Bridge). This will lead to a false view with regards to the ability of the existing road network to cope with the future volumes of traffic arising as a result of all of this development.  The Highways Agency has placed a stop order on the proposed development of 800 houses at Ridgeway Farm because of the potential to send junction 16 of the M4 over capacity.  However, the potential for 1,700 houses under one mile to the north west of Ridgeway Farm does not appear to have raised the same concerns.

Respondent Reference 96 state that “the urban extension to the West of Swindon lies within Wiltshire Council who are not as advanced with their Core Strategy as Swindon Borough Council...They do not want to have the commencement of Tadpole Farm delayed by reference to the potential cumulative impact which is unknown.  However, nowhere is it explained what is meant by the cumulative impact.  Further clarification was sought by the Respondent about the cumulative impact but the Core Strategy does not address this issue.

There is no mention in the Core Strategy of the need for the development at Tadpole Farm to be positively integrated with proposed neighbouring developments.  The Swindon Small Scale Urban Extensions Study (Incorporating the West of Swindon Study technical analysis – January 2008 point 1.3 states that “further joint work will be required with North Wiltshire District Council (now Wiltshire Council) to determine the most sustainable location of these additional dwellings, building on the evidence base of this study”.

It is noted that at the Appeal for Land at Moredon Bridge, West Swindon, Appeal Ref: APP/J3910/A/08/2082566 that each developer with interests in this area is well aware of the collective impacts of the developments.  The Inspectors’ report includes reference to: “Taylor Wimpey, following from its own highway advice, was not prepared to agree with the principle of an access it felt would prejudice delivery of its Ridgeway Farm site”.  

The technical notes accompanying the Joint Study carried out in October 2009 by Halcrow Group Ltd into the impact of 3,000 residential dwellings being built on the western border, done on behalf of Swindon Borough Council, showed that this number of additional houses would take the following junctions over capacity:

·         Purton Road/Akers Way roundabout (eastern arm)
·         Mead Way/Sparcells Drive/Pepperbox Hill Roundabout (southbound arm)
·         Mead Way/Peatmoor Way Roundabout (southbound arm)
·         Callington/Queen Elizabeth Drive Junction of Thamesdown Drive

However, the additional impact of traffic from all the proposed development on the western border is not being considered within the traffic modelling for Tadpole Farm.

As yet, the traffic modelling is not complete, a comprehensive area of search has not been defined and, therefore, the local community cannot access the detail needed to make a full and comprehensive response to the proposed Core Strategy.  At a recent public meeting the Leader of Swindon Borough Council promised ORA that an independent traffic study would be carried out at the Borough’s expense (outside of any potential developers/Halcrow) to provide bias-free traffic data about the likely impact of any development at Tadpole Farm.  So far this has not been carried out and yet negotiations with a developer for Tadpole Farm are at an advanced stage.

Strategic Objective SO7 of the Core Strategy, pg. 19, states that, “...a comprehensive and sustainable transport network will be in place (by 2026) that is efficient, safe, affordable, accessible and easy to understand.  It will support Swindon’s long-term growth, linking existing and new communities, with priority given to walking, cycling and public transport, and will provide a genuine choice of modes”.  However, one of the key elements of the sustainability for the existing NDA was the planned Purton – Iffley Road Link.  This has never been provided (we understand it has been abandoned) and any further expansion of Swindon to the North will increase the volume of traffic on a road network that is already over stretched.  If this cannot be delivered in the short to medium term then there will be a hugely, detrimental impact on existing local communities and the new residents of Tadpole Farm.

Tadpole Farm’s inclusion in the Core Strategy is dependent on a single, local road to the south of the site (Oakhurst Way) to carry traffic via Thamesdown Drive to the A419 or other links.  The Deputy Leader of SBC has already stated that (Oakhurst Way) “is not fit for purpose with all its roundabouts and narrowings”.  Oakhurst Way is a focal point of the Oakhurst community and has a green corridor running from Tadpole Farm to Thamesdown Drive.  This green corridor is a vital link between Oakhurst and the NDA by providing a great walking and cycling opportunity.  Oakhurst Way is a residential road that must be crossed by many vulnerable members of the community accessing local facilities – any increase in traffic leads to increased safety risk to pedestrians and cyclists trying to cross the road.

As the costs of providing a new link to the A419 through Blunsdon will require a huge investment, the local community have been concerned that it will be difficult to mitigate the effects of the additional traffic from Tadpole Farm.  In fact, the Core Strategy states that one of its vision and design principles is “to minimise the impact on existing communities” but there is no detail to support this principle.  ORA are concerned that there is no mitigation for turning a local AVR into a major AVR.

It is not possible to improve Oakhurst Way because of the necessary function of the associated brook with flood defence and there are houses facing directly onto the road.  With the exclusion of the Addinsell Road link (in the proposed Core Strategy 2009 but not in the current Core Strategy) the permeability of the site has been seriously affected with traffic forced to use either Oakhurst Way to the South or Salzgitter Drive to the North) as a link east to all services including the Orbital Retail Park and to connect with Thamesdown Drive to access North to the A419 or South to West Swindon.  This will put pressure on Tadpole Lane.

The Sustainability Appraisal included as part of the Core Strategy states, “Improving public transport links, walking and cycling network will encourage sustainable modes of transport”.  However, this is not supported by development at Tadpole Farm as this area is geographically at the furthest point from the town centre and a minimum of 5 miles from the Eastern Development Area (EDA) which includes the major areas of “good quality employment sites” identified in figure 4, p31 of the Core Strategy.  Residents that take up employment in these areas are unlikely to have the option to walk or cycle.  There is also poor provision of public transport from Tadpole Farm to the Eastern employment areas.  Therefore the sustainable modes of transport recommended in the Sustainability Appraisal are unlikely to be viable.

d.     Education
In the Core Strategy, the Core Theme CT5 (pg 48) states that, among other things, the policy aims to:

·         establish schools at the heart of their communities to deliver wider social and economic benefits for all
·         create and develop inclusive, accessible, supportive and safe learning environments

In CT5 E. it states that, “schools should be sited within the heart of their communities and be designed to provide safe walking and cycling access”. Yet in the same document, in Policy NC5 – Tadpole Farm, the proposal for 1,700 homes at Tadpole Farm includes just two forms of primary school entry, which may be on or off-site, and two forms of secondary school entry off-site (to expand Isambard Secondary School will require a split site with some of the facilities being sited over Tadpole Lane by a footbridge).  This, in the context of the existing severe shortage of places within North Swindon (which is still not complete, with many areas still undergoing further residential development), will result in a need for more families needing to travel to schools other than their local one.  Firstly because the local schools are already insufficient to meet their local demand, and secondly because any new school places will, in all likelihood, not be provided until a later phase of any development after occupancy of earlier phases is already underway.

There is little capacity to expand the existing schools of North Swindon any further, with many sites already incorporating extra forms in either permanent or temporary buildings added since the schools were originally built.  Yet despite this, many families still find themselves unable to enter their children into their local school due to insufficient places within the community they live (it is estimated by the Chair of Governors at Isambard School that there is a current need for 26 secondary forms of entry but only 16 currently exist). Some 300 children are already placed in schools other than their local one and this can only get worse with increased pressure from Tadpole Farm.

This will encourage an increase in journeys to reach the school they are allocated to, with the increased journeys leading both to concerns about the lack of safe routes from the communities to the schools and a burden on roads that are already busy.  All children from Oakhurst have to cross a minimum of one main road (Oakhurst Way) to get to school.

In Policy CT5 C. concerning Special Education Needs (SEN) the Core Strategy states that, “SEN based upon individual and Boroughwide requirements will be met by: Extending existing SEN facilities, Providing Special Resource Provision at new and existing primary and secondary schools”.  There is no mention in the Core Strategy about the conversion of many of the secondary schools in Swindon to Academy status, therefore removing the control of SEN provision and general education provision from the LEA into the control of the school.  This has not been addressed satisfactorily in the Core Strategy and further assurances need to be given to the community.  Isambard Secondary School is likely to have Academy status by September 2011.

e.     Green Infrastructure             
The NDA currently consists of large areas of developed land that typically contain high density housing. In the North and West of the development (Oakhurst) access to Green infrastructure is prevented by the railway line that runs from Purton Stoke to Mouldon Hill.
·         The River Ray and associated green corridor is not directly accessible to residents.  Oakhurst residents to the south of the development can access Mouldon Hill Country Park either by walking or cycling (across private land) However, to go via Thamesdown Drive it is 0.8 miles from the car park to the nearest Oakhurst residence and 1.8 miles to the furthest at Tadpole Lane.

·         To the North, Tadpole Farm provides an area of green open space that is identified as a development area that is designed to provide access to the same green corridor. The proposed corridor is currently privately owned farmland that is not accessible to local residents. 

·         The development is to be linked to “Green Infrastructure” in accordance with Policy CT3 (pg. 37) which connects with the urban area and countryside, particularly the Cricklade Country Way. The proposed development is adjacent to a flood plain and in order to access the proposed Cricklade Country Way it will be necessary to provide new crossings over the railway and River Ray.  In addition the current road crossing at Tadpole lane is unsafe for pedestrians and would require substantial improvement. There is also no provision for pedestrian footpaths or cycle paths on Tadpole Lane.

·         The Small Scale Urban Extensions Study and Swindon Green Infrastructure Strategy highlight the importance of the Cricklade Country Way as a key strategic Green Infrastructure route. Development proposals must support this role and integration with the wider Green Infrastructure objectives, including a landscape strategy, which addresses strategic impact to the north of the site and the relationship between Tadpole Farm and Blunsdon Hill.  Respondent Reference 38 to the 2009 proposed Core Strategy states that, “we are concerned that...the Cricklade Country Way Corridor has not been identified as a critical infrastructure project in the ‘Implementation and Monitoring Plan’ and as such we thus question whether this policy is deliverable”.

·         Appendix 7 of the Core Strategy (pg. 168) states that, “Strategic Green Corridors: are linear that are designed in part to give residents access to natural green space and the open countryside and provide opportunities for recreation. Green corridors increase in value if they are linked to form a network that extends within and beyond the Borough boundary.” It is unclear how this particular Green Infrastructure Route is to be funded.

The local charitable organisations that are supporting the development of the route feel that over £25million is required to provide the required footpaths etc.  There is no indication where the funds will come from and there is no clear indication when or even if the corridor will be completed.
This proposed Green corridor will need substantial investment and may span some 17 miles according to the development plans. The River Ray corridor is already recognised as an area for significant funding concern. 
f.       Brownfield Land
The development of brownfield land can provide new housing on previously developed land enabling people to live closer to shops, services, and places of work, reducing dependency on cars and helping to tackle climate change.  It can also help to bring back into use derelict land and vacant buildings, as well as helping to sustain existing local businesses and assisting in urban regeneration.  By doing this pressure is relieved on greenfield land, therefore protecting the countryside.  However, in the Core Strategy, according to officers of SBC, only 17% of proposed housing will be on brownfield land.

g.     Sustainability: Housing Targets
Housing target figures have been misreported in the Core Strategy for Tadpole Farm. The text on page 108, Section 4.73 needs to be amended to reflect the true facts and the Council needs to explain why the proposed development exceeds the recommended target levels.  The South West Regional Spatial Strategy identified an area of search to the Northwest of Swindon, “to accommodate 2,000 dwellings as urban extensions(s) to Swindon”. The reference in Section 4.73 of “2,000 dwellings” is the total for the area to the Northwest of Swindon, and includes other areas such as Ridgeway Farm and Moredon Bridge. The Swindon Small Scale Urban Extensions Study, January 2008 (pages 59-60) states, “Tadpole Farm could deliver 1,500 dwellings” and “a combination of development between Ridgeway Farm and Moredon Bridge could also make a significant contribution towards the strategy of about 800 dwellings.  Land to the south of the railway can accommodate 600 dwellings, whilst land to the north of the railway can accommodate around 100 dwellings, approximately 50 dwellings on either side of Purton Road on the high land.  Higher numbers could be delivered here at a higher density, however this may reduce the open space provision at this the area, but this needs to be balanced against the selection of other sites to meet the RSS provision.”
 It is noted that any sites to the east of Swindon were outside the scope of the Small Scale Urban Extension Study and therefore, the sustainability of Tadpole Farm is only established in relation to sites in the Northwest of Swindon.  Its overall sustainability in comparison to the whole of Swindon is greatly reduced.
In the Joint Study point 17.44 it is stated that ,” there is a significant lack of jobs within walking distance and even cycling most jobs are at the threshold of the distance” and in 17.45 “consequently the overall assessment is Fair”.  In point 12.26 the disadvantages are listed as being, “furthest from all centres of employment; no single corridor to concentrate investment for improvements” and “traffic disperses through villages and creates numerous local problems”.
The most robust evidence base that was used to inform the old Regional Spatial Strategy for the Southwest (Joint Study) concluded that the most sustainable direction of growth for Swindon was to the East, followed by the Southwest and the least sustainable direction of growth was to the Northwest. Theses finding effectively repeated the findings of the earlier Swindon Principal Urban Area (PUA) Study published in September 2003 which identified the housing capacity of the urban area up to 2016, and an Urban Extensions Study which identified the area to the East of Swindon, south of the A420 and east of the A419, as the most sustainable direction for long term strategic growth of the town.  Yet the Core Strategy seems to have rejected this evidence base.  The Core Strategy proposed to locate a higher number and percentage of these homes in less sustainable urban extensions away from the East of Swindon.
The recommendations of the Swindon JSA Steering Group, and endorsed by the Cabinets of Swindon Borough Council and Wiltshire Council states that the preferred direction of growth is to the East of Swindon. The Strategic Housing Land Availability Assessment (Dec 2008) recommended that the size of the Eastern Development Area should be 12,000 dwellings. However, the Core Strategy now suggests that this was only “up to 12,000 homes” and goes on to state that “as a consequence of the economic downturn the already challenging housing targets are now not achievable”.
It is noted in the East of Swindon Evidence Base Update, Swindon Borough Council, March 2011 that the “the minimum size of development is in the order of 7,500 dwellings for a reasonably self-contained development.” The Core Strategy has adopted this minimum number of homes for the EDA and ORA believe that as most of SBC’s own evidence base has been rejected that the reduction of the EDA is not sound.  The Localism agenda has been applied to the EDA and the communities’ view taken into account.  However, the same criterion has not been applied to the communities’ view in the local area of Tadpole Farm or only applied to a minority view concerning Addinsell Way.  We believe that the Council has not acted fairly or equitably in this matter.

    1. Flood Risk:
The possibility exists that with the combination of continued paving of green open space and the predicted effects of global warming issues of flooding are likely to increase.  This possibility is identified in the Core Strategy Part 1, point 1.15, pg. 18, “The Challenge for Swindon” is that “the impact of climate change has the potential to affect everybody.  Of particular concern to Swindon is the threat of increased flood risk.  However, Swindon also has the opportunity to lead in exemplar sustainable development”.     
Policy CT3 G. pg. 37 states,” To minimise the risk and impact of flooding, development will avoid known areas of flood risk.”
The Tadpole Farm development is to be sited on the edge of a flood plain in an area where the River Ray is known to flood frequently.  When the developers’ consultation drawing is overlaid over the Environment Agencies current flood map for North Swindon it can be clearly seen that the development leaves no room for error.  In the event that climate change were to increase the flood risk, parts of the development would likely fall within any extended flood plain boundary.

In recent years the flood risk area was extended to encompass houses along Tadpole Lane.  Undoubtedly nobody expected the increased flooding and subsequent expansion of the flood plain when planning permission was granted, yet within five years the effect of flooding is very real.  This has had a significant impact on house insurance for local residents and will undoubtedly discourage buyers of new or existing properties.

Policy CT3 G. Pg. 37 also states, “To minimise the risk and impact of flooding, development will not increase the risk of flooding”.   There is a strong feeling amongst local residents that new developments do indeed affect the flood risk and mitigation obligations placed on previous developments have not prevented increased flooding.  The Core Strategy in its current form fails to explain how this will be managed.

How will SBC ensure that developers prove that flood mitigation schemes are effective and sustainable, and that the schemes are future proofed to take account of global warming or future urban expansion?

Policy CT3 Paragraph G. also states, “To minimise the risk and impact of flooding, development will aim to reduce the risk of flooding in nearby communities”.  The Core Strategy makes no attempt to explain how this will be achieved and does little to reduce the concerns of local residents.

The Tadpole farm and Oakhurst developments are situated very close to the River Ray and leave little room for sustainable drainage.  Run off from roads and houses does not have to travel far before it meets the river or surrounding water table.  The sites are also situated on an area of impermeable clay which prevents drainage to subterranean aquifers.  Any significant rainfall in the area overloads the current storm drains and roadside ditches.  Water backing up from the River Ray from rain upstream combined with runoff from existing and new developments is a recipe for disaster. 

This Core Strategy submission was written by the Planning Committee of ORA:
Ian Birch – Chair
Rob Nyman – Vice-Chair
Steph Exell – Secretary
Andrew Oakes – Treasurer
Kevin Ley – Committee Member
Sarah McDermott – Committee Member
Brychan Travers – Minute Secretary