Group have put considerable effort into preparing an impressive amount of
paperwork for this draft and should be congratulated. However it is unfortunate
that a number of key aspects are flawed and must be reconsidered. In
Section 1 Housing
Criteria. Whilst it is a good idea to try to find an objective method to select
development sites this framework is fallible, fails to take into account
important considerations and appropriate evidence has not been used to score
some of the criteria. A hugely important issue not taken into account is the
volume of traffic which travels through the town centre, making the narrow
streets unsafe and causing environmental
H1. This can only be scored if the Local amenities are mapped and given some weighting to
determine where “most” of them are. It is not clear where the measurement is
taken from and to, and might discriminate against larger
1. The explanatory notes do not make it clear where the measurement is taken from and
to, and might discriminate against larger sites. The measurement must take place
along established rights of way and not simply a straight line on a
4. The measurement must take place along established rights of way and not simply a
straight line on a map.
8. The explanation states “pylons and electrical power lines are considered very
unlikely to be resited or removed.” An 11kV high voltage power line with spare
capacity might be considered an advantage as this would enable electricity to be
provided with little difficulty whereas a 33kV line would be difficult to move.
Details of the electricity network have been provided but were not used in the
scoring (apparently aerial photographs were used). North of Filands are two very
large high pressure gas pipelines which have prevented previous development in
the area (a second factory planned by Dyson Appliances in the late 1990s) due to
the high cost of diversion. These have not been taken into
9. See comments under 8 above.
11. This criterion seeks to combine two aspects identified in the Settlement Setting
Assessment and produces a very poor result which has not been endorsed by any
local heritage interest group. The criterion states that even if development
obscures an important view provided the site is between the 75m and 85m contour
lines it will be acceptable. However the Assessment also makes it clear that
Rolling Lowland should be protected of which there is a huge area to the south
of the town around Daniel’s Well and Arches Lane most of which meets the height
requirement. This is the area with the most iconic views both into and out of
the town which must receive special protection.
13. It is unclear what the difference is between Considerable and Very considerable impact
is. As hedgerows and trees are specifically mentioned one would imagine that
very considerable would involve much destruction of such features but this does
not seem to be reflected in the scores.
The scoring for sites 3a and 15 fails to take account of the access difficulties and the
distance to be travelled to get to and from the sites. Looking at the identified
potential access routes;
A. The access at Park Road will require a bridge to be built. The Tetbury Hill access
can only be delivered if the Football Ground is relocated. Persimmon have
suggested moving it on to the development site which will considerably reduce
the space available for housing.
B. Is the only existing access but will require a road of 500m (around the Buffer Zone,
the purpose for which is difficult to understand) to be built. Once this has
been built there seems to be little to prevent further development along it. C
to E are not placed in the correct positions on the map.
C. As well as relocating the Co-op loading bay 2 private gardens would need to be
compulsorily purchased which is highly unlikely to happen.
D. Access would have to go along Poole Road take a sharp right turn and follow the
northern edge of the school site. This would not be suitable for traffic serving
170 houses and business units.
E. Tetbury Hill Gardens is a private road unsuitable for vehicle traffic not a public right
of way and Sunhaven is unlikely to be redeveloped.
F. The extension of Beuttell Way would require the purchase of 3 properties and would
enter the Dyson buffer zone.
The conclusion is that just to provide access will require considerable expense and
the main advantage of the site will fail to be exploited – its proximity to the
town and its facilities. It is therefore unlikely the site is capable of
delivering reasonably priced housing. Instead the most likely sole vehicle
access will be outside the town and be more likely to attract commuters rather
than those wishing to take an active role in our
A far better solution would be to realise the potential which was offered when the Reeds Farm
estate was built in the 1980s of creating a town centre relief road from the
stub of Reeds Farm Road to the Whychurch roundabout and develop site 22b. Whilst
the Worthies must be retained as open space with increased sport and recreation
facilities, the area to its north can be developed without much detriment to the
town’s environs. The bypass, Filands and existing housing to the west provide
physical barriers to the amount of space for development, unlike Backbridge Farm
which has open countryside to its west. This area should be developed in stages
over a period extending beyond 2025. In addition to housing, this could be
considered for the site of a
It must be made clear that further large scale development must not take place until later
in the plan period due to the pressure exerted on our infrastructure by 65% of
the Core Strategy housing requirement having been delivered in the first 8 years
of a 20 year plan.
In view of the paper considered by the Steering Group on 15th April 2013 regarding a
possible extra 70 dwellings on the Cowbridge site there should be a complete
reappraisal of housing sites.
Section 3 Shopping
The evidence does not support the conclusion that a supermarket should be built adjacent to
First various consumer surveys have found that as much as three quarters of the
convenience spend of residents in the Malmesbury area is made outside the area
at Cirencester, Tetbury, Swindon and Chippenham. It is unclear why this is a
‘problem’ which can be cured by one extra local supermarket. Most consumers have
favoured shops, with particular qualities they associate with and as there are
many branches of at least ten different major store brands (Aldi, Asda, Co-op,
Iceland, Lidl, Marks & Spencer, Morrisons, Sainsbury, Tesco and Waitrose)
within 15 miles of the town it is unlikely one local supermarket will have much
Next the results from Neighbourhood Survey are not as clear as set in paragraph 3.1.2.
Question A4 “Do you think the Malmesbury area needs a new supermarket” is
ambiguous. Anecdotally many people took this to mean “Should the Malmesbury area
have a supermarket other than Co-op.” However the result from question A5 is
clear, a majority would not support a supermarket if it had a negative impact on
the High Street. There is overwhelming evidence to show it will have a negative
mpact and the amelioration measures laid out in paragraphs 3.1.4 and 3.1.5
will not wholly alleviate this.
The objective to extend the Town Centre Boundary in paragraph 3.2.3 is unrealistic
and the map on page 36 although based on the Primary and Secondary Frontage
areas R1 and R2 of the North Wiltshire Local Plan does not reflect the present
position. The Secondary Area to the north west of the centre has shrunk so there
is a gap between Gloucester Street and the Triangle with the only commercial
premises being the Old Bell Hotel, not a retail usage. Also there are no retail
premises in Cross Hayes Lane or the east side of Cross Hayes (other than the
cafe premises at 2a Silver Street) and this area should also be removed from the
map. Some listed buildings are no longer sustainable as shops due to changes
resulting from modern requirements such as the Disability Discrimination Act.
This requires buildings open to the public to be fully accessible which often
requires unacceptable alteration to the historic fabric. Therefore each case for
change of use must be viewed on its
Section 4 Business
The shortcomings of the site selection process outlined above relate to this
section, in particular the high pressure gas pipes will probably rule out the
site identified for the Dyson Technology
Paragraph 4.1.2 states Dyson Limited has a need for additional employment land and a
buffer zone. No justification has been provided for the buffer zone. Apparently
there is a suggestion that sensitive research and development might be
compromised by the public being able to get close to the research building. No
evidence has been provided to support this assertion, the public can already get
very close to the building in Beuttell Way (what would stop a rival occupying
one of the units there?) and if sensitive work was carried out in the inside the
building away from external walls there should be no possibility of external
eavesdropping. The only instances of secrets being stolen from this company has
been by persons employed by them.
has been provided to justify the allocation of any employment land in addition
to the area adjacent to the Persimmon Headquarters which has permission for
offices and the Garden Centre site reserved for light industrial. Both sites
have been identified for several years and the fact they remain undeveloped must
demonstrate the lack of demand. As the town had many more workers commuting in
than residents working elsewhere (2001 Census) before the latest round of
recruitment at Dysons it would again suggest there is no demand for more
It is unfortunate that Paragraph 5.7.2 makes no reference to Wiltshire Council’s car
park prices. Whilst the desire to harmonise prices across the county is
commendable it unfortunately does not take other factors into account. In
Malmesbury Station Yard car park is some distance from the town centre with a
steep climb which differentiates it from other car parks in similar towns which
is not reflected in the charges. Prior to the introduction of charges a
temporary extension had to be made. After the introduction of a charge of £1 a
day it was still well used but since the charge increased to £5.60 less than one
quarter of the spaces are usually occupied. This is having a great impact on the
viability of the Town Centre.
8.1 sets out
many aspirations some of which are contradictory and some which are difficult to
envisage how they will be realised. Examples
8.1.4 Task 1, development must contribute to distinctive character (there is no
uniform character, it comprises many different elements and therefore is very
difficult to define), task 2, style must be appropriate to the context, and
paragraph 8.1.7 task 2, use of continuous frontages, are contradictory. Post war
development extending the town in all directions has very little continuous
frontages until the most recent 21st Century development which is not highly
regarded. The layout of developments like White Lion Park, Reeds Farm and
smaller sites on the Swindon Road have become the context of those areas and
are now seen as being very acceptable.
8.1.4 Task 2, style must be appropriate to the context, and task 3, Design and
Access Statements, the Steering Group should not have any role in overseeing
future development – this should be done by the Town & Parish Councils in
association with existing local interest groups. It would be inappropriate for
all new development to replicate the town centre as suggested by the final
8.1.5 Task 1, development must maintain visual connection with the countryside
and task 2, visual impact must be enhancing, both of these aspirations will be
very difficult to deliver.
8.1.6 Task 3, street furniture with a common language, designs &
specifications, must be encouraged but details have to be
8.1.6 Task 5, town centre opportunities for reallocating space, should form part
of section 8.2 but in view of that section seems
this section illustrations are lacking to demonstrate examples of good design.
Some photographs seem inappropriate, on page 18 it is unclear how parking bays
slow traffic (street parking would) and the brick built house of page 19 is
surely not what is expected in
Malmesbury. Settlement Setting Assessment
No description has been given of the views and their relative importance. Views 2
and 3 are of no importance (see paragraph 61 of the Gleeson Appeal’s Inspector’s
opinion), 4 is an uninspired view of new houses and 6 of incongruous brick
houses, all of which should be removed from the document (although T3 and T5
should be retained as Thresholds). The view at T1 should be numbered &
described and the view shown as Figure 6
This section is particularly weak as it does not analyse the strengths, weaknesses and
special features of particular areas around the town. The areas to be given
protection are not clearly identified. No mention has been made of Park Road
which has the following special qualities; part of the river valley, it and Park
Lane are the only remaining examples of country lanes adjacent to the
settlement, must be kept free of traffic if the river walk is to be extended to
Back Bridge and the rising ground screens the White Lion Park development
It is not clear what is meant by Sustainable Edges, local topography does not offer any
way to limit development. The fact that past development has occurred on land
between the 75m and 85m contour lines does not provide a good guide for the
future. The phenomenon of sprawl could be prevented by framing development by
physical features, for example the bypass, Filands and Reeds Farm.
Malmesbury Neighbourhood Steering Group
What others are saying about our Draft Neighbourhood Plan Over 500 residents have already looked at the draft plan. These are the comments that they have made about it.
Our consultation runs from the 5th of March 2013 to April 26th 2013. These are the published comments received up to 08/03/13.
All comments below were submitted to this online feedback portal. We hold the identity and addresses for each submission and have decided not to publish them unless specifically requested by the person who submitted them.