WHSAP has allocated six housing sites in Trowbridge.
H2.1 at Elm Grove Farm,
H2.2 Land off the A363 at White Horse Business Park,
(H2.3 Elizabeth Way)
H2.4 Church Lane
H2.5 Upper Studley
H2.6 Southwick Court.
All, bar Elizabeth Way at H2.3, lie in the flight corridor used by the bats that roost in the nature reserves at Green Lane Wood and Biss Wood and feed in Southwick Country Park. Wiltshire proposes that 595 houses be built on these five sites.
Here is a map that shows how the development of these sites will close the gap between Trowbridge and the villages of Southwick and North Bradley and interrupt the bats’ flight corridor.
The WHSAP sites are in yellow and the bats’ flight corridor is marked with black arrows.
There is a National Planning Policy Framework which was revised and published in 2019. The WHSAP, submitted in 2018, was written to meet the requirements of the 2012 version of the NPPF, but we see no reason why the newly written policies should not meet the new requirements.
The 2019 NPPF lays out guidelines for the UK’s planning authorities. In paragraph 170 it says:
Planning policies and decisions should contribute to and enhance the natural and local environment by:
[. . .]
d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
and in paragraph 174, it goes on:
To protect and enhance biodiversity and geodiversity, plans should:
a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and
b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.
Bechstein bat by Jan Svetlik (CC BY SA 3.0)
We welcomed the draft Trowbridge Bat Mitigation Strategy and are happy to see its inclusion into the plan’s policies, but we feel that those policies do not yet meet the NPPF’s requirements. They will not sufficiently safeguard the wildlife corridors and stepping stones that connect them or the coherent ecological network that links Southwick Country Park to the bats’ nature reserves in the east of Trowbridge.
If the bats’ are to survive the urbanisation of the green corridor that links their maternity roosts to their feeding grounds, the policies need to be very, very specific. Phrases such as appropriate infrastructure and management protocols will just not do; they sound like weasel words with no real meaning and we fear they are there to provide wriggle room.
There should be no wriggle room. We are in the middle of an environmental emergency and Wiltshire Council needs to step up and take control of the development of our town. We would like to suggest that there is room for an overall policy for these five sites that calls for very specific infrastructure, managed specifically for the benefit of our coherent but threatened ecological network.
Please join us in assessing the WHSAP Schedule of Further Main Modifications. Add your comment to the public consultation:
+ online via the council’s consultation portal;
+ by email using this representation form and returned to email@example.com (a word version of the representation form can be found on the council’s consultation portal);
+ or by post in writing to: Spatial Planning, Economic Development and Planning, Wiltshire Council, County Hall, Bythesea Road, Trowbridge, Wiltshire, BA14 8JN