Site Address: Land at Station Works, Station Road, Tisbury, SP3 6QU
Proposal: Outline planning application for redevelopment of the Station Works site to provide a mixed development of up to 86 dwellings, a care home of up to 40 bedspaces with associated medical facilities, new pedestrian and vehicular access and traffic management works, a safeguarded area for any future rail improvements, and areas of public open space.
Date and Venue of Inquiry: The inquiry will open at 10:00am on Tuesday 21 February 2023 at Marlborough Room, Red Lion Hotel, 4 Milford St, Salisbury SP1 2AN.
The appeal will be attended by the local planning authority, the appellant, and a presiding inspector. An Inspector appointed by the Secretary of State will hold the inquiry, opening on the date shown above to decide the appeal. Members of the public may attend the Inquiry and at The Inspector's discretion, express their views.
Planning Inspectorate Reference: APP/Y3940/W/22/3308919
JOINT PARISH COUNCIL RESPONSE
1. This submission is made on behalf of SEVEN Parish Councils bordering Tisbury for which Tisbury is their Local Service Centre. The parish councils that have come together to produce this document are:-
· Sutton Mandeville
2. The seven parish councils have come together because they share the same concerns about the proposed Station Works development. Whilst individual parish councils are also making their own submissions tailored to local concerns, it was felt that a combined submission would demonstrate and emphasise the shared concerns and objections felt by all members of the group.
3. This group made a submission to Wiltshire Council outlining their concerns and objections to the scheme. We do not want to repeat the contents of that submission which we stand by, but request that those comments together with this document are fully considered as part of the appeal process.
Vision for Tisbury
4. We think Tisbury is a great place and want to see it continue to thrive. We agree that the Station Works site should be re-developed, but consider the current proposal inappropriate and unnecessarily harmful in many ways.
5. The Wiltshire Core Strategy has an exciting vision for Tisbury’s future and the perceptive appreciation of what Tisbury values and needs conveyed by the document is well supported by those living in Tisbury and in the surrounding villages. It understands that Tisbury has development constraints, but provides a vision for the way forward that gives growth and opportunity while recognising and minimising the potential adverse impacts.
6. This is illustrated by the following extracts from the Wiltshire Core Strategy in relation to Tisbury:-
“Local Service Centres will provide for modest levels of development.”
“Modest growth of both housing and employment to ensure development is balanced, thus helping to minimise out-commuting.”
“Service centres will become more self-contained and less need to travel.”
“Modest new growth in Tisbury will take account of the constraints presented by narrow access roads”.
7. The Wiltshire Core Strategy balances the desire for growth with the constraints of its size, current infrastructure, level of public services and the limited road network serving Tisbury.
Implications of Proposed Scheme
8. Regrettably the current planning submission does not provide modest levels of development, modest growth of both housing and employment, a balanced mixed development, minimal out-commuting, a more self-contained village, less need to travel or take account of the constraints presented by narrow access roads.
9. 86 dwellings and a substantial care home is not modest development in the context of Tisbury. Furthermore the proposed level of housing provision is out of kilter with the need to balance this with employment opportunities. This is going to encourage and increase out commuting, not help to minimise or make the Tisbury Local Service Centre more self-contained or reduce the need to travel.
10. In terms of sheer numbers, Tisbury needs four new homes a year to meet its 2036 target. We appreciate this is not a ceiling, but there are reasons why this level has been set.
11. With such a large number of dwellings coming available in one go, the benefits to Tisbury residents and families will be limited. There is not sufficient demand from local people at any single point in time to take proper advantage of this vast stock of new homes. Modest ongoing growth would be much more beneficial to Tisbury, providing dwellings now and into the future.
12. With such a large over supply of dwellings in one go, the vast majority will be occupied by new people coming into the area and with no expansion in job opportunities, out commuting will increase, not decrease.
13. The new care home will offer employment opportunities, although limited and unlikely to exceed the current employment level on the site. Also given the current difficulties with care home staffing in Tisbury, the staff recruitment is expected to come largely from the wider community beyond Tisbury.
14. Notwithstanding this limited and only employment opportunity offered by this planning submission, the case for proposing a care home seems misplaced. Firstly it’s generally accepted that there is not sufficient demand for a care home of the proposed size in Tisbury, but furthermore it is tucked away ostracised from the life of the village, has poor access into the village, cannot at this time be adequately serviced by Tisbury Surgery and will generate significant additional traffic. Traffic will be generated by family and friends visiting, medical and treatment/therapy attendances, goods deliveries, waste disposal and 24/7 staffing.
Impacts of Proposed Scheme
15. It is evident from the extent of objections from Tisbury residents and from Tisburys’ parish councils that this development is not welcomed and in fact firmly rejected. This is also the situation with our parishes surrounding Tisbury.
16. We want Tisbury to thrive and for us to have good access into our Local Service Centre. We also do not want to exacerbate the traffic problems we are experiencing on our local roads.
17. The proposal to halve the road capacity immediately outside the development, by closing one arch of the railway bridge to vehicles is a retrograde step. The current bridge arrangement is far from ideal and this closure is an unreasonable imposition by the developer. The arches/tunnels are prone to flooding, a problem difficult to remedy because the level of the roadway is below the flood level of the adjacent river. It was only thanks to having two tunnels that the road could be reopened reasonably promptly when a vehicle incapacitated by the flood water in 2021, blocked one of the tunnels. Closing one arch to traffic will likely cause access issues for emergency vehicles both to the site as well as to neighbouring villages.
18. There are various estimates for the expected increase in traffic arising from the proposed development. These are typically between 10 and 15%. However our position is not dependent on this figure.
19. All Local Service Centres in Wiltshire: Pewsey, Market Lavington, Cricklade, Mere, Downton and Wilton are served by an “A” road, except Tisbury. Worse still, Tisbury is not served by a B road either! It is served at best by “C” roads, but also non classified roads.
20. When these roads were built they did have spare capacity, but successive Tisbury development - Churchill estate, Lady Down, High View, Castle Mount, Spring Field Park, Snows Hill, Paradise Meadow, Oddford Vale and the 90 home Wyndham Place have more than taken up the spare capacity.
21. We now have everyday difficulties due to limitations of the road network providing access to Tisbury. The principal routes linking Tisbury to the major road network are all subject to constraints that hinder and often prevent the free flow of traffic. Parishioners in our respective parishes are constantly raising real concerns that the limits of these feeder roads have been reached.
22. The major roads that come nearest to Tisbury are the A303, A30 and B3089. The only way to get from these major roads to Tisbury is via a network of country lanes taking you through the local villages and hamlets. Whilst the country lanes are limiting in themselves there are also pinch points and other hazards along these roads that give rise to congestion, altercations between drivers and collisions.
23. It is the limitation of these routes into Tisbury that we want to bring to your attention. These are as follows:-
24. From Hindon to Tisbury. A feeder to Tisbury from A303, A350 and B3089. Initial pinch points in Hindon High Street where flows are single file in alternate directions, the road then has to pass through the single-lane skewed tunnel at the apex of the hill and on a near right-angle bend, where visibility is very poor, necessitating vehicles to reverse on a slope to allow an oncoming vehicle through. On Hindon Lane coming into Tisbury itself, traffic flows have to alternate making this a difficult and congested access and egress to and from Tisbury. Conflicts are inevitably occurring at these pinch points and this limits the capacity of this road in
and out of Tisbury.
25. From Fonthill Bishop to Tisbury. Feeder from A303 and B3089. This passes through the Grade 1 Listed arch into Fonthill Park. The arch is a single carriageway, so cars in opposite directions have to alternate. As well as the width constriction, the vertical line of sight is poor
26. From Chilmark to Tisbury. Feeder from A303 and B3089. Chilmark has an ancient road alignment with sharp right-angle bends, which are difficult for
vehicles to negotiate. The difficulty for lorries is self-evident, but cars have similar
difficulties staying on their half of the road on these blind corners, making it particularly dangerous. Houses in the centre of Chilmark village are positioned
right up along the road edge, with no pavements.
27. From Dinton and Fovant into Tisbury via the Chicksgrove Road. This 3.5 mile road links Tisbury to the A3089 near Dinton and via Fovant to the A30. There is no road speed restriction despite the road’s steep undulations, curved alignments and restricted width. Sections of this road suddenly narrow into pinch points, causing additional hazards. Conditions along nearly half the length of the road have worsened considerably since it was designated the sole access for HGVs servicing warehouses on the Fonthill Estate. On this road there are frequent collisions and incidents and it is one that many try to avoid.
Collision at pinch point between Upper & Lower Chicksgrove. Police in attendance
Car that left the road at right angled bend at Ham Cross
28. From A30 through Swallowcliffe to Tisbury. Swallowcliffe has a significant stretch of single track road, where vehicles can only pass in one direction at a time. You cannot see to the other end of this narrow stretch, requiring vehicles to back up when they meet. Frequent altercations occur
29. From A30 through Ansty to Tisbury.
Single track section of road in Ansty on the route linking the A30 to Tisbury. You cannot see to the other end of this narrow stretch, necessitating vehicles to back up when they meet. Altercations occur, as in the instance shown where there is a refusal to back up and in the meantime more vehicles arrive compounding the problem.
30. We should reiterate that these photographs show the principal routes into Tisbury. There are no wider roads serving Tisbury and these roads are therefore used by all traffic, cars, vans, lorries, buses etc.
31. It is instructive to compare the situation described above, which is based upon the experience of residents, with the Appellant’s evaluation of the Local & Strategic Roads Network in Campbell Reith’s Traffic Assessment (TA).
32. The Local Road Network is considered in just three TA clauses, 4.12 – 4.14 and is based solely on the stretch of road just outside the Station Works site, called Jobbers Lane. It states, “The carriageway width is typically 5.8m and is subject to a 60mph national speed limit in the vicinity of the proposed access”. There seems to be no further consideration of the Local Road Network and therefore the constraints which limit the capacity of these roads, which we have identified above, has been entirely missed.
33. So when the traffic generation analysis is then applied to an inadequately identified Local Road Network, ie 5.8m wide, high speed roads, it leads to their false conclusion stated in clause 6.9 that, “It is not considered that the Proposed Development will have any material impact on the existing road network in terms of highway capacity or highway safety”.
34. The TA also shows a lack of understanding of the Strategic Road Network, which is described in clause 4.15 of the TA, identifying the A303 and A350, with the A350 giving access to the south. There is no mention of the A30 which is the strategic route for traffic going south from Tisbury. Drivers from Tisbury are very unlikely to head for the A350 to head south, instead taking the much quicker route to the A30 through Ansty or Swallowcliffe to join the Strategic Road Network.
35. The traffic issues we are experiencing in the villages and access routes to Tisbury are unique to their locations and these situations are not covered by a traffic manual. We believe little, if any, data is held by highways departments on these problems and hence they tend to be ignored when considering these sorts of Planning Applications. However they are a reality and fully recognised by local residents who experience them on a daily basis.
36. There are passing references in the Neighbourhood Plan that traffic on the minor roads needs to be addressed in submissions, but it tends to be lost at the application assessment stage, perhaps as other issues are deemed more important or because other issues are more easily resolved. But for many people, this is a significant issue in their daily lives and one that has a significant impact.
37. In addition to the road restrictions at specific locations on the access roads to Tisbury, there are adverse impacts which are of a more general nature.
38. Typically the access roads to Tisbury do not have pavements to walk on and so you are walking in the road, often without a clear line of sight to spot oncoming vehicles. More vehicles will make walking in the road more hazardous. This is worse at night as there are no street lamps.
39. The access roads often have limited lines of sight for pedestrians to see oncoming vehicles in time to take evasive action. Worryingly there are many instances where there is no verge and therefore nowhere to escape.
40. There are many instance of cottages and houses with their front walls in close proximity to, or fronting the road. The occupants of properties in close proximity to the road can feel the vibration and hear the noise of the passing vehicles, which is intrusive and not pleasant. Pollution from exhaust is also a factor that should be considered.
41. There are many examples of cottages and houses in close proximity to the road, but for reasons of confidentiality we do not want to show pictures of them.
42. Where two vehicles travelling in opposite directions pass on the lanes, they are typically up against the verge where pedestrians walk. There is concern that increasing the number of vehicles, increases the risk of being squashed at the side of the road.
43. Vehicles take up the full width of the road and sometimes more, which makes walking in the road dangerous.
44. In addressing the desire to develop the Station Works site, we should carefully take stock of what makes Tisbury a successful village and Local Service Centre. There is a lot it can lose. The proposed scheme brings very little in terms of opportunity or enhancement, but comes with a significant downside. This downside is best summarised by the huge number of objections from across the community and the minimal support for the scheme.
45. There is a clear way forward which does have support, and this is contained in the Wiltshire Core Strategy. Regrettably the submitted scheme does not begin to recognise this vision or make any meaningful attempt to align with its strategy. Instead it provides almost exclusively dwellings, which will be of limited benefit to Tisbury and detrimental in so many ways.
46. Adverse traffic impacts are a major concern and extend from the proposed closure of a bridge arch immediately outside the Station Works site, to numerous issues in the surrounding villages. A lack of access to Tisbury has always been recognised as a major constraint and this has not been considered in this submission.
47. It is evident from the Traffic Assessment (TA) with this submission that insufficient work has been done by the Appellant’s team to identify the nature and constraints of the Local Road Network. This is woefully lacking in their TA submission and hence their analysis and subsequent conclusion that the proposed development will not have any material impact on the existing road network, is simply not the case. The traffic analysis has to model the actual Local Road Network and put simply, this has not been done.
48. As we have illustrated, the roads serving Tisbury have specific constraints, single track and no oncoming visibility, 90 degree bends, restricted widths, hazardous alignments etc and these are the factors that limit their capacity. This needs to be recognised in the planning of a development at Station Works and hence the emphasis in the Wiltshire Core Strategy on making Tisbury more self-contained, lessening the need to travel, minimising out commuting and taking account of constraints presented by narrow access roads.
49. We believe the shortcomings and loss of opportunity this scheme presents and the damage it would cause, can only lead to one conclusion and that is that this application should not be given permission to proceed.
Submitted on behalf of the parishes of:-
Ansty, Chilmark, Fovant, Hindon, Sutton Mandeville, Swallowcliffe and Teffont