Wool Parish Council response to the proposed Dorset Local Plan (February 2021)
Wool Parish Council are confined to responding only to Chapter 7: South Eastern Dorset Functional Area - Section 21: Wool. Our Parish has just finished consulting on The Purbeck Local Plan and it would appear that our opinions and indeed the conclusions of Dorset Council’s own plan have been ignored in terms of proposed housing numbers for Wool in The Dorset Local Plan. Wool Parish Council request that this section of the Dorset Local Plan is removed in its entirety, to be replaced by the relevant section of the Purbeck Local plan.
Wool Parish Council consider holding a consultation during a national lockdown completely unacceptable. The demographics of Wool Parish are such that there is a significant proportion of the Parish without access to the internet. The 2019 Wool Neighbourhood Plan survey which delivered a leaflet to every household in the parish resulted in a 32.5% response by paper. It was only at Wool Parish Council’s request that Dorset Council made paper copies of the plan in Wool library (a quarter of the way through the consultation). Plans were available in all other libraries from the start of the consultation. To add insult to injury, Dorset Council refused Wool Parish Council’s request for the consultation to be extended by 3 weeks so that Wool Parish Council could try to reach as many parishioners as possible. Wool Parish Council do not believe that Dorset Council have made the effort to properly consult.
Comments on specific points in the plan
Referring to 21.1.3, a brief statement is made referring to “areas of the village [that] have experienced flooding from surface water run-off”. Wool Parish Council would like to point out that there is ongoing enquiry with regard to this problem (which has occurred more than once).
Wool Parish Council requests that any reference to Thomas Hardy is removed from any vision for Wool. The fact that a writer based a location in a story on a house just outside of Wool does not justify a reference to Thomas Hardy being included in the vision for the village
There is absolutely no evidence to support the view that expansion of the DIP will require or justify the number of houses previously envisaged, let alone the newly introduced extra 400 houses. Many of the already-built units at the DIP remain unoccupied; the original specifications for occupancy of hi-tech companies has been diluted to allow general industrial purposes to be allowed (catering, for example); the numbers of genuinely local people who work at the DIP is very small – estimated at the last consultation to be not in excess of 5% of the total workforce on the DIP site; the latest major expansion (to provide the Ministry of Defence with a technology centre) will provide only 90 local jobs over a ten year period, i.e. 9 per year…. the latest 1,500 jobs are in fact MOD posts which will not be filled by local people. How is it possible to know that the skills required by any possible future expansion at the Dorset Innovation Park can be met by existing residents and/or new residents to the new developments associated with Wool & East Burton?
Section 21.3 also reiterates the proposal for a 65-unit extra care facility. This merely continues the inflation of the agreed 470 houses from the first consultation; there has never been any evidence-based justification produced for this facility and it is strongly suspected locally that there is no actual need for it. That said, if the would-be developer thinks that this provision is genuine and would satisfy an evidence and statistics led requirement, then any such facility should have applied to it restrictive covenants preventing change of use or purpose. A similar development was allowed in the Charminster area – designated as ‘extra care units’ – these are now commercially available properties on the open market. If any developer thinks that there is a genuine need for this facility, the developer must agree to such covenants being applied to those proposed for Wool.
Section 21.3.1 and 21.3.2 introduce the additional 300 houses proposed at East Burton, and the 100 extra houses proposed for south of Hillside Road. The numbers of houses proposed in the 2018 Purbeck Local Plan consultation was apparently justified by the SHMA (since acknowledged to have been flawed); this assessment has since been revised downwards, meaning that an increase (almost a doubling in fact) of proposed houses for Wool cannot possibly be justified even on the basis of the SHMA. Secondly, there is no acknowledgment in the Dorset Local Plan as far as it relates to proposed development in Wool of the now accepted impact of changes to government planning legislation (biodiversity, green space erosion, and revision of SHMA formulae etc) nor of the impact – yet to be fully quantified – of Brexit and the Covid pandemic, the effects of both of which are likely to be felt for some considerable period. It is likely therefore that the implied – and genuine - need for extra housing is going to be non-existent. In addition, it is appropriate to revisit the view that the proposals for numbers of houses for Wool are based not on NEED but rather on GREED. Reference to the Housing Needs Register has shown consistently throughout the last few years that whilst a certain number of social and affordable housing units are required in Wool (around 24 according to the Gold and Silver Bands) these numbers – which have remained more or less constant – would only justify building a maximum of 250 houses (based on the minimal 10% government requirement); were the aspirational figure/ratio of 40% as put forward by Purbeck District Council as an inducement to agree with the then-proposals to be followed, then a maximum of only 80 market value houses could be justified. There is absolutely no available evidence that local employment expansion could ever possibly justify these numbers of houses.
Section 21.3.3 makes reference to the provision of a SANG. There is insufficient detail to decide whether or not what is hinted at would actually be delivered. The lack of exactitude makes it impossible to comment on proposals, but based on what has previously been stated (in the Purbeck Local Plan), we wish to put on record that the specification and description of the proposed SANG contains errors and the location selected offers little benefit to residents of the western end of Wool, north of the A352 who will have suffered noise pollution, poor air quality, biodiversity loss due to the construction of the proposed housing. The selected SANG site is a considerable distance further than the new housing and approached by a narrow road with no footway, after crossing the A352. Whether the proposed replacement of elderly conifers in North Wood with native deciduous trees will in any way counteract the negative effects of this disturbance, and of increased footfall on the ground flora and wildlife, is doubtful. Any such detrimental effects negate the core aim of a SANG. (v) No details of management of the 17 hectares agricultural land with the ancient monuments are given, other than protecting the latter from tillage. A SANG must enhance biodiversity and provide a public space for leisure, and well-being. If this area is a SANG, what are the plans? How does this area fulfil the criteria for a SANG?
Section 21.4 appears to indicate where Dorset Council Planners wish to take Wool. Far from the idyllic/bucolic ‘Vision’ which would see Wool retain a rural village character with enhanced green spaces, 21.4.1 suggests that Wool is one of the larger villages within Dorset and with the development that is proposed over the plan period, an improved centre for main town centre uses would be beneficial. Planning a rural village and planning a village with a main town centre are surely mutually exclusive. This section also further reveals the lack of local awareness of the Planning Department. This section of the proposal goes on to mention that new retail and office uses should be focused near to the existing retail units along Dorchester Road between The Square and Collier’s Road. This could be delivered through the redevelopment of existing sites especially those uses that are not typically found in town centres; Does the community have any wish for such developments, much less any need for them? It is also worth pointing out that any such development would require removing Wool and Bovington Motors (a long-established local family business which does offer genuinely local employment opportunities) along with existing other businesses (hairdresser and pharmacy) which are greatly valued by the local community. Also, Wool Parish Council would like to point out that the road referred to it called ‘Colliers Lane’ not ‘Colliers Road’.
Section 21.5 refers to Main Development Opportunities. his section also refers to Bovington and Bovington Garrison, claiming that it is “well connected to the village” – this is simply not the case. Feedback obtained through the emerging Wool Parish Neighbourhood Plan has highlighted the lack of transport between Wool and Bovington as a key issue. Wool Parish Clerk is currently working with the Garrison Liaison Office to try to improve the connectivity between Wool and Bovington. The garrison cannot be used as a justification for expanding housing as again, the two entities are mutually, politically and economically exclusive of one another.
Section 21.5.8 refers to “significant opportunities to improve access to Dorset Innovation Park and the railway station”. It goes on to mention improving car parking at the station. Again, this reveals a lack of reality – there are no routes between the station and the DIP that can be developed – the newly designated cycle route (along Colliers Lane via Breachfield) is not used as it is a long-cut rather than a time-saver, and the hugely expensive cycle route along the Dorchester Road is used by pedestrians and dog-walkers, not by any quantity of cycling commuters. The East Burton Road is far too narrow to allow a safe cycling route, meaning that the claims being made in the document are simply not feasible. As a final point, the only location at the station for extending car parking is the area to the east of the old goods shed; this is an area which Network Rail has consistently said is not available.
SITES FOR ADDITIONAL HOUSING (21.5.9, 21.5.10, 25.1.12 21.5.13)
As has already been discussed in this response, the Purbeck Local Plan finalised that the Wool should be required to accept up to 470 houses. This was changed (subtly but significantly) in the Main Modifications to “around” 470, with an additional 65 ‘extra care units’ (the future use of which is extremely doubtful without restrictive covenants): this already means that 470 has become 535 new builds – which is a rather elastic definition of “around”… There cannot be any possibility of increasing this ‘agreed’ number yet again (if the views and wishes of this community are to be respected). To do so would make a complete mockery of the previous consultation.
It is further noted that in 21.5.13 (which refers to an optional additional site to the south of Hillside Road) that whilst the land probably does have the capacity to deliver around 100 new homes it is rather concerning that the paragraph goes on to state that it would help to meet the medium-term housing needs of the area whilst the sites to the west are being developed , which rather implies that it is already being assumed that it would be delivered as a development site before the main site of 470+ houses to the west of the village. It is also the case that the statement: It could deliver a very different housing product to the areas to the west and complement provision in the village is sufficiently vague and specious as to meaningless.
The key to the whole development proposal lies hidden away in 21.5.14: Additional housing growth at Wool would help to support and improve the facilities within the area and provide more opportunities for people to live in the village. Nobody would deny that Wool needs a certain amount of housing development – but the key word is NEEDS. Concern has been voiced time and again throughout this extenuated process that what is being proposed is not designed to satisfy the genuine NEED of the existing community, but rather to satisfy the GREED of any would-be developer. There is no evidence-based need for anything remotely approaching the effectively 535 houses provided for under the Purbeck Local Plan, much less the 935 houses which the Dorset Plan would allow. When the statement suggests that it would and provide more opportunities for people to live in the village, what it really means is that it would provide the developer the opportunity to profit from developing a dormitory town for people wishing to move away from the Bournemouth/Poole conurbation.