Agent Person ID: To correct EXAM/34 : delete "e" from "theose", to read "those": i.e., "those Natura 2000 sites".

Transcription

1 24 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Para.5.137, bullet pt. 7: spelling mistake in EXAM/34 (NB. mistake not made in SOCG/33 or EXAM/56) Person To correct EXAM/34 : delete "e" from "theose", to read "those": i.e., "those Natura 2000 sites". Issue: SOCG33 error This error in EXAM 34 is acknowledged. The proposed modification however is correct.

2 23 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para. 5.92, bullet pt. 5: is incorrectly transcribed in EXAM/34. SOCG/33 and EXAM/56 correctly read as follows: development which with potential to Increase s [delete s ] recreational pressure upon the Salisbury Plain Special Protection Area will be required to provide proportionate contributions towards the maintenance of the Stone Curlew Management Strategy, [footnote] to offset impacts through the Wessex Stone Curlew Project designed to avoid adverse effects upon the integrity of the stone curlew population as a designated feature of the SPA To correct EXAM/34: delete not be permitted unless and replace with be required to provide in the first sentence of para.5.92, bullet 5. Issue: SOCG33 error This error in EXAM 34 is acknowledged. The proposed modification is however correct.

3 22 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para.5.75, bullet pt. 9: the word protected in the first sentence has been incorrectly transcribed as protecting in EXAM/56 and EXAM/34. SOCG/33 for this bullet pt. correctly reads: Survey is required of the potential impacts of development on protected bats (including roosting, foraging grounds and commuting routes) associated with the Savernake Forest bat roosts and other species.... To correct EXAM/56 and EXAM/34: change protecting to protected, to read protected bats. Issue: SOCG33 error This error is acknowledged and the change should be made.

4 21 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para 5.59, bullet pt. 12 is incorrectly transcribed in EXAM/56 and EXAM/34 SOCG/33 has correct wording for this bullet pt: all development will be planned and delivered in accordance with Wiltshire Council guidance required to maintain the integrity of the Bath and Bradford on Avon Bats Special Area of Conservation (SAC), having particular regard to the Wiltshire Bats SAC Guidance. [footnote 8] To correct EXAM/56 : the words be required to should be inserted between will and maintain To correct EXAM/34: the words will be required to should be inserted between development and maintain. Issue: SOCG33 error This error is acknowledged and the change should be made.

5 20 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para 5.19, bullet 17 is incorrectly transcribed in EXAM/56 SOCG/33 and EXAM/34 have correct wording for this bullet pt: development which with potential to increase s [delete s ] recreational pressure upon the Salisbury Plan Special Protection Area will be required to provide proportionate contributions towards the maintenance of the Stone Curlew Management Strategy [footnote 1] to offset impacts through the Wessex Stone Curlew Project designed to avoid adverse effects upon the integrity of the stone curlew population as a designated feature of the SPA To correct EXAM/56: the word Mitigation should be changed to Management, to read Stone Curlew Management Strategy. Issue: SOCG33 error This error is acknowledged. Bullet point 17 should refer to 'stone curlew management strategy' and NOT 'stone curlew mitigation strategy'

6 19 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para 5.19, bullet pt. 16 is incorrectly transcribed in EXAM/56 and EXAM/34 SOCG/33 has correct wording for this bullet pt. as follows: development in the vicinity of the River Avon Special Area of Conservation (Hampshire) or Salisbury Plain Special Areas of Conservation must protect incorporate appropriate measures to ensure that it will not adversely affect the habitats, species and processes which maintain the integrity of those Natura 2000 sites ese Special Areas of Conservation To correct EXAM/56 and EXAM/34 : the words avoidance/mitigation (between appropriate and measures ) should be deleted from this bullet pt. Issue: SOCG33 error This error is acknowledged and the change should be made.

7 37 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Suggest: correct spelling mistake. Person Core Policy 59, bullet pt. iv, second sentence: spelling mistake in EXAM/34 : effect, not affect. Issue: Spelling mistake Agreed and should be corrected in future versions of the plan.

8 1 Mr Rod Eaton Person Ministerial statement: Local Planning and Onshore Wind Person There should be no windfarms in Wiltshire. Summary of Reasons Below: We have to stand up against the Big Wind lobby bullying and bribing nearby home owners to gain planning permission. These are the reasons: 1) Technically, wind is intermittent and cannot be dispatched like efficacious power plant (fossil and PWR nukes); peak wind rarely coincides with peak demand. 2) Wind often meets as little as 0.1% of demand and needs coal and/or gas spinning reserve running at inefficient low loads to cover the sudden drops. The alternative is using OCGT distillate oil plant which can be run up in a few seconds but is very expensive. 3) Wind costs us dearly through obscenely huge strike price subsidies paid directly by the electricity consumers. On-shore wind is paid double the 50 per MWh pool price. 4) Wind farms despoil our countryside to no advantage except making some land owners rich. 5) The Capacity Factor reduces with age and it is only 24% to begin with. This is why it was never developed before. It gets more costly as it ages. 6) Wind is paid not to generate as it cannot be made available when it is needed but can be left to churn out its pathetic output at all the wrong times at huge cost either way. 7) It reduces house prices in the vicinity and health issues are rife from the low frequency noise emissions. Wind farms are enormous eyesores, spoiling views. 8) It cannot be stored without huge expense on more pumped storage (itself a net user of power). 9) As a low density energy source (like even more expensive solar follies) it takes-up many hectares of land to produce little output compared with gas, coal, oil or nuclear. 10) We gave up wind for steam over 100 years ago. Wind is unreliable and retrogade for our lifestyles. The ultimate control of our lives will be the so called smart grid which if, heavens forbid, is ever enacted will cut off individual appliances in our homes when the wind drops. Frack on for shale gas and of course a return to coal plant such as Germany has just been doing, having just built 29 new coa-fired power stations with another 10 on order. Renewables are a failure except for hydro which, on investigation, you will find is the predominant renewable in Germany (vaunted as such a green country).

9 Issue: Local Planning and Onshore Wind In line with national planning policy, addressing climate change is a strategic objective (paragraph 3.5, page 16 of the Core Strategy, Tracked Changes Version). CP42 presents a clear, positive and flexible position on the support for renewable energy schemes. However, as the demand for energy needs a balanced set of supply options, the policy does not favour any particular form of technology. In preparing the Plan, the council has presented detailed evidence to support a balanced and flexible approach to the delivery of renewable energy schemes. As such, there is a case for the development of sensitively planned developments that meet the criteria set out in CP42. The council and representors presented their respective positions on these matters through the relevant hearing session. As such, the Inspector has before him all the relevant information to determine whether the Plan (as amended) is sound on this particular issue.

10 26 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person To correct EXAM/36: change Bechsten to Bechstein. Person Para , new bullet pt. following bullet pt.15 incorrect spelling of Bechstein in EXAM/34 Issue: SOCG33 error This error is acknowledged and the change should be made.

11 46 Dr Kate Fielden The Avebury Society Vice-Chairman Person Person We have noticed two further errors in the Draft Core Strategy, EXAM/34, re the Natural Environment that were overlooked in the drawing up of SOCG/33 (CPRE ID. No ): Core Strategy, Appendix A, p.263 : Ashton Park Urban Extension: Ecology, bullet pt.3: Applications will be screened for potential impacts on the Bath and Bradford SAC. Any appropriate assessment must conclude no likely significant adverse effects. To correct : alter wording as indicated in red in EXAM/34 and insert change into EXAM/56. Reason: As it currently stands this statement is not compatible with the legal requirement re Appropriate Assessment under the Habitats Directive. Suggested change indicated in red would rectify the statement. Issue: correct legal requirements of the Habitat Regulations The matters raised do not relate directly to a proposed modification, however it is agreed that deletion of likely significant' is necessary to provide an accurate account of the requirements of the Habitat Regulations is required and should be made in future versions of the plan.

12 41 Dr Kate Fielden The Avebury Society Vice-Chairman Person Person Ref. Comment H422; change H558 (CPRE and Avebury Society); and Comment m423; change 94 (EH and WC SOCG, Feb 2013). CS, Para : suggest change to reflect news of adoption of Statement of OUV by World Heritage Committee, June 3013, and to rectify incorrect transcriptions: The Stonehenge, Avebury and Associated Sites World Heritage Site was inscribed on the UNESCO World Heritage List in 1986 for its OUV. Since that time a Statement of Significance (see Stonehenge Management Plan (2009, pp ) and a draft Statement of OUV for the WHS (agreed 2013) have been drawn up. [New f.n.: remove the word Draft ; and add agreed June 2013, as appropriate.] The World Heritage Site of the World Heritage Site requires protection and where appropriate enhancement in order to preserve sustain its OUV. Not all aspects of the WHS contribute to OUV and the UNESCO Statement s [ add s ] of Significance and Draft OUV as well as the World Heritage Site Plans for Stonehenge and Avebury are a critical resource in reaching decisions relating to the significance of its elements, for identification of its attributes of OUV, [ delete comma ] as well as other important aspects of the WHS, and on reaching decision s [ add s ] on the effective protection and management of the Site. To correct : please rectify incorrectly transcribed (corrected here in red) and ensure that they are recorded in EXAM/56 and EXAM/34. Note : it is suggested that preserve is altered to sustain [highlighted in green] for consistency elsewhere in the Core Strategy, e.g. HS59. Issue: Improving the sense of the paragraph The matters raised do not relate directly to a proposed modification, however it is agreed that the suggested further minor change improves the sense of the sentence and should be accepted.

13 25 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para 5.143, bullet pt.3, new bullet pt. has been incorrectly transcribed in EXAM/56 and EXAM/34. NB. the bullet pt. has been split into two. SOCG/33 correctly reads: Add a bullet point: " all development will be required to maintain the integrity of the Chilmark Quarries Special Area of Conservation, having particular regard to the Wiltshire Bats SAC Guidance[footnote 1]" To correct EXAM/56 and EXAM/34: delete "planned and delivered in accordance with Wiltshire Council guidance" and replace with "required". Issue: SOCG33 error This error is acknowledged and the change should be made.

14 32 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Historic Environment Person Note: The following errors, originally appearing in EXAM/13 during the EiP, were pointed out in an from Kate Fielden to Mr David Milton (Wiltshire Council) on 8 July The errors were not corrected n EXAM/13 and they reappear in EXAM/34; they are not recorded in EXAM/ Ref. Comment m421; change 93; WC and EH SOCG February 2013) CS, para The paragraph should read: Wiltshire s World Heritage Site (WHS) is a designated heritage asset of the highest international and national significance. The United Kingdom, as a signatory to the Convention Concerning the Protection of the World Cultural and Natural Heritage (UNESCO 1972) is obliged to protect, conserve, [add comma] and present and transmit to future generations its WHS s [add s ] which, because of their exceptional qualities are considered to be of Outstanding Universal Value (OUV) of the World Heritage Site and ensure that it is transmitted to future generations. This obligation should therefore be given precedence in decisions concerning development management in the WHS. World Heritage status offers the potential of considerable social and economic gains in areas such as sustainable tourism ; [add semi-colon] however this will require careful and sensitive management in order to protect the Site and sustain its OUV. To correct : please rectify incorrectly transcribed (corrected here in red) and ensure that they are recorded in EXAM/56 and EXAM/34. Issue: transcription error Agree that there is a surplus reference to the World Heritage Site in this sentence which can be deleted without altering the meaning of the paragraph, which should be made in future versions of the Plan.

15 33 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person 2. Ref. Comment H422; change H558 (CPRE and Avebury Society); and Comment m423; change 94 (EH and WC SOCG, Feb 2013). CS, Para : suggest change to reflect news of adoption of Statement of OUV by World Heritage Committee, June 3013, and to rectify incorrect transcriptions: "The Stonehenge, Avebury and Associated Sites World Heritage Site was inscribed on the UNESCO World Heritage List in 1986 for its OUV. Since that time a Statement of Significance (see Stonehenge Management Plan (2009, pp ) and a draft Statement of OUV for the WHS (agreed 2013) have been drawn up. [New f.n.: remove the word Draft'; and add agreed June 2013', as appropriate.] The World Heritage Site of the World Heritage Site requires protection and where appropriate enhancement in order to preserve sustain its OUV. Not all aspects of the WHS contribute to OUV and the UNESCO Statement s [ add s' ] of Significance and Draft OUV as well as the World Heritage Site Plans for Stonehenge and Avebury are a critical resource in reaching decisions relating to the significance of its elements, for identification of its attributes of OUV, [ delete comma ] as well as other important aspects of the WHS, and on reaching decision s [ add s' ] on the effective protection and management of the Site." To correct: please rectify incorrectly transcribed (corrected here in red) and ensure that they are recorded in EXAM/56 and EXAM/34. Note : it is suggested that preserve' is altered to sustain' [highlighted in green] for consistency elsewhere in the Core Strategy, e.g. HS59. Issue: transcription error The matters raised do not relate directly to a proposed modification, however it is correct that a transcription error has been made and agree with change.

16 34 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person 3. Ref. Comment m427; change 97 (EH and WC SOCG, February 2013) CS, Para : suggest change third sentence to rectify incorrect transcription: In addition separate management plans set out strategies and actions needed for the successful conservation and management of the site in order to sustain its OUV, [add comma] taking into account of the site alongside other relevant values and interests including tourism, farming, nature conservation, research, education and the quality of life of the community. Issue: How the sentence reads Agree that sentence needs improving and that this can best be achieved by inserting a comma after OUV, and deleting 'into'.

17 35 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Suggest relevant inserts made. Person 4. CS, Paras and : suggest need additional ref. in f.n.70 and f.n.72 to UNESCO agreed Statement of OUV (June 2013). Issue: improving references Agree that the suggested insertion will help clarify the footnote and the change should be made.

18 38 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person We have noticed two further errors in the Draft Core Strategy, EXAM/34, re the Natural Environment that were overlooked in the drawing up of SOCG/33 (CPRE ID. No ): Core Strategy, Appendix A, p.263 : Ashton Park Urban Extension: Ecology, bullet pt.3: Applications will be screened for potential impacts on the Bath and Bradford SAC. Any appropriate assessment must conclude no likely significant adverse effects. To correct : alter wording as indicated in red in EXAM/34 and insert change into EXAM/56. Reason: As it currently stands this statement is not compatible with the legal requirement re Appropriate Assessment under the Habitats Directive. Suggested change indicated in red would rectify the statement. Issue: correct legal requirements of the Habitat Regulations The matters raised have been discussed through the Examination hearing sessions and do not relate to any proposed modifications. However it is agreed that the change of likely significant' is necessary to provide an accurate and consistent account of the requirements of the Habitat Regulations is required and should be made in future versions of the plan.

19 39 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person We have noticed two further errors in the Draft Core Strategy, EXAM/34, re the Natural Environment that were overlooked in the drawing up of SOCG/33 (CPRE ID. No ): CS, Appendix A, p.267, West Warminster Urban Extension: Ecology, bullet pt. 5 : Financial contributions towards the stone curlew conservation project required to offset recreational impacts upon management strategy designed to avoid adverse effects upon the integrity of the stone curlew population as a designated feature of the Salisbury Plain Special Protection Area To correct : alter wording as indicated in red in EXAM/34 and insert change into EXAM/56. Reason : As it currently stands, this bullet point refers to a now-defunct project and is therefore inaccurate. Elsewhere in the CS where this defunct project was mentioned, the alternative wording suggested in red, above, has been agreed between WC and CPRE (ID No ; SOCG/33); e.g., CS, p.122, para.5.137, bullet pt. 5. Issue: Change to improve accuracy The matters raised have been discussed through the Examination hearing sessions and do not relate to any proposed modifications. However it is agreed that change proposed should be made in the interests of accuracy and consistency with other to the plan.

20 40 Dr Kate Fielden The Avebury Society Vice-Chairman Person Person Ref. Comment m421; change 93; WC and EH SOCG February 2013) CS, para The paragraph should read: Wiltshire s World Heritage Site (WHS) is a designated heritage asset of the highest international and national significance. The United Kingdom, as a signatory to the Convention Concerning the Protection of the World Cultural and Natural Heritage (UNESCO 1972) is obliged to protect, conserve, [ add comma ] and present and transmit to future generations its WHS s [ add s ] which, because of their exceptional qualities are considered to be of Outstanding Universal Value (OUV) of the World Heritage Site and ensure that it is transmitted to future generations. This obligation should therefore be given precedence in decisions concerning development management in the WHS. World Heritage status offers the potential of considerable social and economic gains in areas such as sustainable tourism; [add semi-colon] however this will require careful and sensitive management in order to protect the Site and sustain its OUV. To correct : please rectify incorrectly transcribed (corrected here in red) and ensure that they are recorded in EXAM/56 and EXAM/34. Issue: Improving the sense of the paragraph It is agreed that the suggested further minor change improves the sense of the sentence and should be accepted.

21 42 Dr Kate Fielden The Avebury Society Vice-Chairman Person Person Ref. Comment m427; change 97 (EH and WC SOCG, February 2013) CS, Para : suggest change third sentence to rectify incorrect transcription: In addition separate management plans set out strategies and actions needed for the successful conservation and management of the site in order to sustain its OUV, [add comma] taking into account of the site alongside other relevant values and interests including tourism, farming, nature conservation, research, education and the quality of life of the community. Issue: Improving the sense of the paragraph The matters raised do not relate directly to a proposed modification, however it is agreed that the suggested further minor change improves the sense of the sentence and should be accepted.

22 43 Dr Kate Fielden The Avebury Society Vice-Chairman Person Suggest relevant inserts made. Person CS, Paras and : suggest need additional ref. in f.n.70 and f.n.72 to UNESCO agreed Statement of OUV (June 2013). Issue: Footnote reference The matters raised do not relate directly to a proposed modification, however it is agreed that the suggested further minor change improves the sense of the sentence and should be accepted.

23 45 Dr Kate Fielden The Avebury Society Vice-Chairman Person Suggest: correct spelling mistake. Person Core Policy 59, bullet pt. iv, second sentence: spelling mistake in EXAM/34 : effect, not affect. Issue: Spelling mistake The matters raised do not relate directly to a proposed modification, however it is agreed and should be accepted.

24 47 Dr Kate Fielden The Avebury Society Vice-Chairman Person Person We have noticed two further errors in the Draft Core Strategy, EXAM/34, re the Natural Environment that were overlooked in the drawing up of SOCG/33 (CPRE ID. No ): CS, Appendix A, p.267, West Warminster Urban Extension: Ecology, bullet pt. 5 : Financial contributions towards the stone curlew conservation project required to offset recreational impacts upon management strategy designed to avoid adverse effects upon the integrity of the stone curlew population as a designated feature of the Salisbury Plain Special Protection Area To correct: alter wording as indicated in red in EXAM/34 and insert change into EXAM/56. Reason : As it currently stands, this bullet point refers to a now-defunct project and is therefore inaccurate. Elsewhere in the CS where this defunct project was mentioned, the alternative wording suggested in red, above, has been agreed between WC and CPRE (ID No ; SOCG/33); e.g., CS, p.122, para.5.137, bullet pt. 5. Issue: Change to improve accuracy Agreed that the deletion of the sentence indicated improves the accuracy of the bullet.

25 27 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person CR147; HS19: Core Policy 59 supporting text, para.6.70 : change asworded in EXAM/56 and EXAM/34 does not agree with change agreed in SOCG/33 as set out under Proposed change (HS16) to [old] para 6.67, bullet pt.1. SOCG/33 reads: A number of strategic mitigation plans and guidance documents are also available to ensure that the most commonly occurring effects upon international sites can be avoided as efficiently and effectively as possible [footnote]: To correct EXAM/56 and EXAM/34 : delete mitigation in this sentence. Issue: SOCG33 error This error is acknowledged and the change should be made.

26 2 Mr Stephen Webb Person Guidance for Renewable and Low Carbon Energy Person There appears to be a conflict with the Council's proposed interim guidance on wind turbine separation distances (Core Policy 42, Section 6.38) and this central government guidance which states that: Are buffer zones/separation distances appropriate between renewable energy development and other land uses? 16. Local planning authorities should not rule out otherwise acceptable renewable energy developments through inflexible rules on buffer zones or separation distances. Other than when dealing with set back distances for safety, distance of itself does not necessarily determine whether the impact of a proposal is unacceptable. Distance plays a part, but so does the local context including factors such as topography, the local environment and near-by land uses. This is why it is important to think about in what circumstances proposals are likely to be acceptable and plan on this basis. It would seem that the Council's position on separation distances is unnecessarily obstructive and should be dropped. Consideration of renewable energy proposals should be handled on a case-by-case basis in relation to the existing government guidance. There is no need to wait for new local guidance and certainly no need to have this restrictive policy in place for an unspecified interim period. Should there be any delay in arriving at new local guidance the Council risks being unable to hit their own targets for renewable energy. Issue: Local Planning and Onshore Wind The matters raised have been discussed through the Examination hearing sessions and do not relate to any proposed modifications. In line with national planning policy, addressing climate change is a strategic objective (paragraph 3.5, page 16 of the Core Strategy, Tracked Changes Version). CP42 presents a clear, positive and flexible position on the support for renewable energy schemes. However, as the demand for energy needs a balanced set of supply options, the policy does not favour any particular form of technology. The council accept that the publication of the government's national planning guidance in relation to on-shore wind development does now provide greater clarity in relation to the need, or otherwise, for separation distances between wind turbines and built development. However, the council remain of the view that the text introduced at paragraph 6.38 should be read as guidance and does not, in itself, diminish the overall policy support for renewable energy schemes established in CP42. After-all supporting text cannot operate as policy.

27 The council and representors presented their respective positions on these matters through the relevant hearing session. In addition, the latest policy guidance (Exam/61) has been presented for comments since the closure of the examination hearing sessions. As such, the Inspector has before him all the relevant information to determine whether the Plan (as amended) is sound on this particular issue.

28 28 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Core Policy 66, 2 nd para., bullet pt.1 has not been correctly transcribed in EXAM/56. (It has been correctly transcribed in EXAM/34.) SOCG/33 and EXAM/34 read as follows: "i. The A350 national primary route at Yarnbrook/West Ashton will be improved. The improvement works necessary will be identified through further study work including detailed bat survey information on Annex II species. The design and layout of any such improvements will incorporate sufficient mitigation measures to ensure that important commuting routes for AnnexII species are protected" To correct the wording of EXAM/56 : delete "incorporate sufficient mitigation measures to". Issue: SOCG33 error This error is acknowledged and the change should be made.

29 29 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Core Policy 69, 1 st para, has been incorrectly transcribed in EXAM/34. SOCG/33 and EXAM/56 read as follows: "In order to avoid and reduce potential environmental effects on the River Avon SAC, development will need to incorporate measures during construction and operation to avoid and prevent pollution and mitigate potential disturbance effects; appropriate schemes of mitigation measures may include consideration of suitable buffer zones along watercourses, habitat enhancements and river access management measures. All development within 20m of the river banks should submit a Construction Management Plan to the Local Planning Authority to ensure measures proposed during construction are satisfactory. Where additional sewage discharges to a STW cannot be accommodated without measures to offset phosphate loading, development will be required to undertake proportionate mitigation measures (which may include contributions towards those measures identified in the Nutrient Management Plan) to demonstrate that the proposals would have no likely significant effects adverse affects upon the SAC" To correct EXAM/34 : restore "no" (deleted in error) in last sentence, to read: "... to demonstrate that the proposals would have no adverse effects upon the SAC". Issue: SOCG33 error This error in EXAM 34 is acknowledged. The proposed modification however is correct.

30 30 Mr George McDonic Campaign to Protect Rural England - Wiltshire Branch Chairman Person Person Para (New Forest National Park): typographical error in EXAM/56 and EXAM/34. (NB. This typo is not found in SOCG/33) To correct EXAM/56 and EXAM/34 : place full stop after disturbance at the end of first sentence and begin new sentence with capital letter ( Adverse ). Issue: SOCG33 error This error is acknowledged and the change should be made.

31 88 Mr George McDonic Network Against Wiltshire Sprawl Person Sustainability Appraisal (SA) Addendum (August 2013) CR1, HS224 Person The SA Report Addendum of August 2013 considers over 300 to the Wiltshire Core Strategy and decides that only one has any significance, the remainder being......minor to improve the clarity of the document, that is the Core Strategy. This is extremely surprising and of course it is not correct. The first proposed modification, CR1 or HS224, removes all text for Targets, Monitoring & Review and Delivery Responsibility. These will be incorporated into the Wiltshire Monitoring Framework. The SA Report Addendum concludes that this is not significant. Clearly the change is highly significant for Sustainability. The Monitoring Framework is the instrument or system which, among many other things, should ensure that sustainability interests as identified in the Sustainability Appraisal are maintained and that unforecast problems are identified and resolved. The SA Report Addendum should assess the change as significant and assess the Monitoring Framework for the Wiltshire Core Strategy 2013 to ensure that it is fit for the purpose of ensuring that sustainability is maintained. It will then discover that it is not. Appendix D to the Sustainability Appraisal/Strategic Environmental Assessment, Sustainability Appraisal Report, Focussed Consultation Document of September 2012 sets out Wiltshire s Key Sustainability Issues. Targets and Indicators for these are inadequately covered in the proposed Monitoring Framework. Further, proposed amendment CR1 removes Review and Delivery Responsibility to the Wiltshire Monitoring Framework. The Wiltshire Monitoring Framework For The Wiltshire Core Strategy 2013 does not contain an adequate explanation of the process of Programme Management of the implementation of the Core Strategy. It does not set out how the situation revealed by monitoring is to be assessed and how modifications or corrections are to appraised, put out for consultation if necessary and who is responsible for each stage. There can be no confidence in the system. The SA Addendum should address these deficiencies as they affect sustainability and have them corrected.

32 Issue: Sustainability Appraisal The Council consider that the SA is an accurate appraisal of the. It is the case that during discussions at the EIP sessions the Council offered to review the approach to monitoring and targets and to consolidate them into a supporting technical document. The targets have not been deleted only made more precise or complimented by new targets where appropriate to ensure that the efficacy of polices can be more accurately monitored and reviewed. The next steps and timetables were submitted by the Council and agreed at the end of the EIP hearing sessions. Should the Inspector be minded to find the Plan as modified, sound or capable of being made sound with further modifications, then there will be further opportunity for him to request additional technical work and consultation if deemed necessary. No change necessary at this stage.

33 67 GPSS Government Pipelines and Storage S Person Miss Rachel Cliffe Fisher German LLP on behalf of the GPSS Surveyor Person Fisher German acts as land agents to the Government Pipelines and Storage System (GPSS), we would ask that the GPSS is given due consideration in accordance with the Land Powers Defence Act If you require location plans of the GPSS please contact your land charges department or utilise Issue: Safeguarding Government Pipelines and Storage Systems (GPSS Fisher German acting as agents were consulted regularly through the Core Strategy production process, including the choice of Strategic Site Allocations and also the Infrastructure Development Plan. Any safeguarding zones have been acknowledged in the plan (e.g. Hampton Park in Salisbury), and written into the relevant development template. No overarching objections have been raised. There will be further statutory consultation where there are GPSS issues through the planning application process to ensure that the legal requirements of the Land Powers Defence Act 1958 are met. This is considered adequate to demonstrate that GPSS has been and will be given due consideration in the Plan and process. No further change necessary.

34 68 Mrs Beverley Cornish Downton Parish Council Clerk Person Mrs Beverley Cornish Downton Parish Council Clerk & RFO Person Downton Parish Council is very supportive of the to Core Policies 1, 2 and 3 and 24 and particularly Core Policies 2 and 3 where it states that: 'Other than in exceptional circumstances identified in paragraph 4.25 Development will only be permitted outside of the limits of development, as defined on by the Proposals Map policies contained within the Plan, will only be pe rmitted where it has been identified through. The limits of development may only be altered through community-led planning policy documents including neighbourhood plans, or a subsequent development plan document which identifies specific sites for development' and Yes Yes ' Developers proposing to connect to a Waste Water Treatment Works will need to check with the utilities provider that there is adequate capacity. Development in areas with no mains foul system will need to ensure that there are suitable options available for sewage disposal'. No, the Proposed Modification does not meet a previous objection Issue: Support to Core Policies 1, 2 and 3 and 24 Support noted.

35 95 Mr Jack Mason Wiltshire Community Wind Energy Person Guidance for Renewable and Low Carbon Energy Person Proposed Core Policy 42 (as documented in the Exam/34 document) remain. Planning practice guidance for renewable and low carbon energy paragraph (from Exam/61) 14. Policies based on clear criteria can be useful when they are expressed positively (i.e. that the proposals will be accepted where the impact is or can be made acceptable) The current wording of policy 42 is not expressed positively as defined in the new guidance. Therefore considered. Suggested replacement text Proposals for standalone renewable energy schemes will be supported subject to satisfactory resolution of all site specific constraints. In particular proposals will be accepted where it can be demonstrated that the impacts on the following factors have been satisfactorily addressed: etc. Issue: Core Policy 42 In terms of the council's position in relation to renewable energy, the council considers that policy position (CP42) is positively presented, flexible and supportive of renewable energy schemes. However, it is important to emphasise that at the time the Plan was submitted, specific issues in relation to wind turbines and safety were (and remain) key considerations for the council. However, The Core Strategy, along with the wider development plan, should be read as a whole. As such, all renewable energy schemes will be subject to consideration against the range of policies in order to assess their suitability, including: CP 42 (Standalone energy installations) CP 51 (Landscape) CP 57 (Design) CP 58 (Heritage) and policies of the adopted Waste Development Framework (WCS3 [CPP/60] and WDC12 [CPP/61]). Therefore the Council contends that the Core Strategy strikes an effective balance to ensure that future options for addressing climate change can be taken where they are in all other respects environmentally acceptable. The council accept that the publication of the government's national planning guidance in relation to on-shore wind development does now provide greater clarity in relation to the need, or otherwise, for separation distances between wind turbines and built development. However, the council remain of the view that the text introduced at paragraph 6.38 should be read as guidance and does not, in itself, diminish the overall policy support

36 for renewable energy schemes established in CP42. After-all supporting text cannot operate as policy. The council and representors presented their respective positions on these matters through the relevant hearing session. In addition, the latest policy guidance (Exam/61) has been presented for comments since the closure of the examination hearing sessions. As such, the Inspector has before him all the relevant information to determine whether the Plan (as amended) is sound on this particular issue.

37 87 Mr George McDonic Network Against Wiltshire Sprawl Person Sustainability Appraisal (SA) Addendum (August 2013) CR15 (HS69) and CR24 (HS183) Person HS69 inserts at least in front of the proposed figure of 178 ha of new employment land. This follows the September 2012 insertion of at least into paragraph 4.28 relating to housing figures. There has been a creeping increase in potential development figures. HS183 adds two significant amendments. The first says The total level of new homes is the total over the plan period 2006 to 2026 for each community area are shown as at least. thus confirming the housing increase. The second says For strategic sites, the level of housing to provided are not at least but indicative of the level of homes that should be delivered on these sites. The exact figures will be determined through the master plan process. (sic) What does this mean? It could mean that the strategic housing figures, which are a major part of the totals, are no longer at least and that therefore potentially they have been reduced. This in turn could mean that the overall total figures given in Table 1 at page 23 should not be shown as at least. This would be a substantial change and would require amendments throughout the Core Strategy Document. It could mean that a shortfall in the figures for a strategic site had to be made up by increases at other sites in the community area in order to retain the validity of the overall at least. This would have sustainability implications for the other sites. It could mean that the at least figures did not apply to an individual strategic site but had to be met across Wiltshire as a whole. This would also have sustainability implications. The amendment says that the exact figures will be determined through the master plan process but since such plans cover only a single strategic site they cannot cover any knock on effects elsewhere. It is not clear what the overall Program Management system is. HS69, the September 2012 amendment and HS 183 taken together imply cumulative potential increases in housing, increases in employment land and uncertainty as to the location and quantity of new housing at strategic sites. A particular concern is the cumulative effects of proposed development on the A350, added to by recent and possibly worsened by due to development at some strategic sites being not at least leading to more development at others. The SA has already drawn attention in its consideration of several community areas to a possible requirement for dualling as a result of proposed developments before these were made. Clearly the have sustainability implications. The SA Report Addendum should assess their significance. If it is not possible to do so

38 because of the ambiguities in the current version of the Core Plan the SA should make it plain that the Plan is not fit for purpose. Issue: Sustainability Appraisal The introduction of at least' into the wording will not result in housing development that is open ended, without limit of that will far exceed the figures set out in the Plan. Housing development over and above sites identified in the Plan is subject to a range of policies to ensure it is acceptable and, in particular, housing proposals encroaching into countryside are only permissible under very limited circumstances specified by the Plan. The wording provides a sufficient degree of accuracy to proposed scales and distribution of new housing for monitoring purposes whilst preventing any false impression of a ceiling or arbitrary limit to housing development. It represents an appropriate balance of flexibility and certainty. Brownfield housing development has a high priority. Settlement limits impose a presumption against housing development encroaching into the countryside. This approach has not been changed. Phrasing housing requirements as at least does not diminish the degree of priority attached to the delivery of brownfield land over the loss of countryside. The target has been informed by evidence on the capacity of brownfield land in the County acquired through Strategic Housing and Availability Assessment and other sources.

39 146 Ms Margaret Willmot Salisbury Campaign for Better Transport Hon Secretary Person Sustainability Appraisal (SA) Addendum (August 2013) Person The Sustainability Appraisal Report Addendum indicates that "that only one proposed change to the Core Strategy is considered likely to lead to a change in the significant sustainability effects previously envisaged", that change being the change to Core Policy 41. This overlooks which have the potential to lead to significant sustainability effects, including the following: - CR1, HS224 removes all text for Targets, Monitoring & Review and Delivery Responsibility from the Core Strategy and these are now incorporated into the Wiltshire Monitoring Framework (which does not form part of this consultation). However as the Sustainability Appraisal indicates "The SEA Directive requires the significant environmental effects of plans and programmes to be monitored, in order to identify at an early stage unforeseen adverse effects and to be able to take appropriate action where necessary." The targets and monitoring regime therefore form a critical part of the Core Strategy/Sustainability Appraisal and the indicators which are used need to be subject to scrutiny and consultation to ensure they are fit for purpose. - As separate representations on the Core Strategy CR23 and CR233 have noted, these seemingly allow to the Infrastructure Delivery Plan (IDP) to be made at will and there is no indication as to how or whether being made will be subject to Sustainability Appraisal. As examples, the revised IDP dated Sept 2013 (EXAM/66A-EXAM/66W) contains projects such as WC011 (in EXAM/66V) 'Capacity improvements to the A36'. This scheme does not feature in the Core Strategy, nor in the previous IDP, nor in the Salisbury Transport Strategy Summary (STU/216), The assessment of this scheme presented to the Swindon and Wiltshire Local Transport Body in July 2013 (EXAM/44) indicates that there would be (among other consequences) a slight adverse on Biodiversity and a Moderate Adverse on Water Environment (on the highly protected River Avon SAC). This scheme is not considered in the Sustainability Appraisal delivered with the Core Strategy, nor in this Addendum. The process whereby are made to the IDP without being included in the Core Strategy or considered in the Sustainability Appraisal is not in conformity with the legal requirement to evaluate the impact of development and its associated infrastructure and consider reasonable alternatives. Issue: Sustainability Appraisal It is the case that during discussions at the EIP sessions the Council offered to review the approach to monitoring and targets and to consolidate them into a supporting technical document. The targets have not been deleted only made more precise or complemented by new targets where appropriate to ensure that the efficacy of polices can be more accurately monitored and reviewed. The next steps and timetables were submitted by the Council and agreed at the end of the EIP hearing sessions. Should the Inspector be minded to find the Plan as modified, sound or capable of being made sound with further modifications, then there will be further opportunity for him to request additional technical work and consultation if

40 deemed necessary. All stages of plan preparation have and will continue to meet the Council's legal requirements with respect to the SA. No change necessary at this stage.

41 12 Mr Vivian Vines Dauntsey Parish Council Clerk Person Person My Council considered the Schedule of Modifications at their Meeting held on Monday 2 nd September 2013 and asked me to forward their comments to you. It was agreed that the Clerk should respond to the Consultation stressing that it is important that, although Dauntsey was no longer considered to be a sustainable core village, some development must be allowed over the Strategy period otherwise Dauntsey will become neglected and lose what services and infrastructure that already exists and simply become a dormitory for urban areas. The Parish Council trusts that their observations will be taken into consideration prior to formal adoption of the Core Strategy. Issue: Dauntsey, Chippenham This representation does not relate directly to a proposed modification. However, Dauntsey is identified as a small village, within the Malmesbury Community Area, in the settlement hierarchy and one where the historic boundary is to be removed. In accordance with Core Policy 2 this will mean that new development will be permitted within the village subject to those criteria set out under the sub-heading, outside the defined limits of development. It is considered that this will strike an effective balance between ensuring that modest levels of development are permitted to add to the ongoing vitality of the settlement but at the same time ensuring that levels are proportionate to its size, character and levels of self-containment. No further change necessary.

42 72 Bob Hillman Swindon Borough Council Senior Planner (LDF) Person Person With reference to Wiltshire Council s consultation on the Schedule of Proposed Modifications (EXAM/56 ), including the Sustainability Appraisal (EXAM/57) and Habitats Regulations Assessment (EXAM/58) Addendums, these are minor alterations and consequently I can confirm that Swindon Borough Council does not wish to make representations or objections on grounds of soundness or legal compliance. In relation to the conformity of the Core Strategy (as proposed to be modified) with the Ministerial Statements on Local Planning and Onshore Wind (EXAM/59), and Onshore Wind; (EXAM/60) and the National Planning Practice Guidance for Renewable and Low Carbon Energy (EXAM/61), the Borough Council has no representations or objections to make. Issue: Swindon Borough Council The comments are noted.

43 96 Mr Jack Mason Wiltshire Community Wind Energy Person Guidance for Renewable and Low Carbon Energy Person Proposed Core Policy 42 (as documented in the Exam/34 document) remain. Planning practice guidance for renewable and low carbon energy paragraph (from Exam/61) 16. Local planning authorities should not rule out otherwise acceptable renewable energy developments through inflexible rules on buffer zones or separation distances WCS Paragraph 6.38 The proposed Core Strategy is not consistent with national policy on separation distances. Therefore the policy is because it: i. Will not support sustainable development. ii. Not based on sound evidence. iii. Not consistent with national policy. In particular the inclusion of interim separation distances as proposed in the wording in 6.38 will effectively stop all wind power developments in Wiltshire indefinitely. It is clear that there is no intention in national policy to introduce separation distances. The reference to separation distances should be removed. Issue: Core Policy 42 It is important to emphasise that there is a difference between policy and supporting text. As such, the council remain of the opinion that the actual wording of CP42 (including the additional criteria introduced through Proposed Change 180) is positively written and presents clear support for all forms of renewable energy installations, thereby delivering against Strategic Objective 2 of the Plan. The amendments to supporting text at paragraph 6.38 reflected genuine concerns expressed at the time the Plan was submitted for examination in terms of the need to exert careful control over wind turbines in order to protect local communities. However, the council would wish to express the