Appeal 6004352

The appeal is dismissed.

The Wilshire Local Plan Review (LPR) is underway. Due to the early stage of the LPR, and the extent of unresolved objections, I afford limited weight to the LPR.

A Unilateral Undertaking (UU) dated 08 May 2026 was submitted during the appeal for a contribution towards [name] (BNG) monitoring. The Council were given the opportunity to comment on the unsigned draft of the same obligation. Given the similarities between the draft and signed UUs, I do not consider that any party would be unfairly prejudiced, and I therefore have had consideration to this in my decision.

The Council’s 4th reason for refusal related to the absence of sufficient information in relation to the effect of the proposal on heritage assets of archaeological interest. The appeal is supported by a [name] of Investigation for [name] ([name], September 2025) and an [name] ([name], September 2025) which did not form part of the planning application (the archaeology reports). The Council were given the opportunity to comment on these reports. Therefore, I do not consider that any party would be unfairly prejudiced, and I have had consideration to these reports in my decision. The archaeology reports set out that following a field evaluation, no archaeological features were found within the site. The Council has now confirmed that it no longer has an objection to the development’s effect on heritage assets of archaeological interest. The main issues are defined accordingly.

The main issues are: - the effect of the proposal on highway safety and the highway network; -whether the site is in a suitable location for the proposal having regard to local and national development objectives for the location of development and accessibility; and -whether the proposal makes adequate provision for BNG.

The site comprises part of an arable field which is flanked to the north by the C292 and to the east by the Council’s salt store and a site with planning permission for 2 factory facilities1 (the [name] development). To the south and west the site is bordered by agricultural fields. The site is located at [site address] and the [site address] Business Park and the [site address] crossroads, which mark the intersection of the A345 and the C292, are located to the east. A petrol garage is located at the crossroads.

The appellant is a precision engineering company which manufactures components for the defence, aerospace, medical, pharmaceutical and sub-sea industries. The appellant currently operates from a site approximately 400m to the east of the appeal site close to the junction with the A345. The submission sets out that the appellant has outgrown the existing premises and that site constraints limit the space for additional specialist manufacturing equipment and the storage of raw materials which has restricted the existing capacity for productivity and growth. It is stated that larger bespoke premises are necessary to support long-term growth which would see a planned increase in skilled staff from 24 to 40 employees in addition to operational efficiencies through the storage of more raw material.

The proposal is for the erection of 2 buildings of 3,712m2 GIA and associated external areas, access, parking and landscaping which would be occupied by the appellant following a relocation from the existing premises. The buildings would be in class E (office), B2 (General industrial) and B8 (storage and distribution) uses and would be separated by a service yard. A bell-mouth entrance is proposed to the northern boundary, providing access from the C292, along with a separate pedestrian access onto the C292 at the northeastern corner of the site.

The submission sets out that, accounting for the planned growth in staff numbers, the development would result in 15 additional staff vehicle movements on the local highway network in the AM and PM peak hours. A scenario whereby the development is built out and occupied by another occupier within the same use class has also been modelled, and this would result in 33 additional vehicular movements in the AM peak hour and 24 in the PM peak hour. The appellant submits that these movements would not represent a significant increase in the number of vehicles on the local highway network, and would be within the range of existing day-to-day fluctuations on the C292 and at the junction with the A345. It is stated that in both scenarios HGV delivery vehicle movements would not be materially different to the current operation.

It is the appellant’s intention to retain the existing site for storage, and I heard at the hearing that this would result in infrequent vehicular movements. However, whilst I 1 Application reference 19/09327/FUL acknowledge the appellant’s desire to operate in this manner, this may not always be the case and other operators may operate differently, including the potential for increasing vehicular movements from the existing site and/ or severing the operation of the existing and appeal sites. The combined vehicular movements for the operation of the appeal and existing sites have not been modelled. The impacts of the operation of both sites on the local highway network are unknown and thus the ability of the network to accommodate them is untested. This casts doubt on the capacity of the highway network to accommodate the vehicular movements generated by the proposal as well as any potential benefits arising from the reduction of vehicles reversing into the existing site.

The appellant’s existing premises are sited close to the junction with the A345 and access involves a limited section of the C292 and the relocation would bring new vehicular movements along the C292. The submission is not supported by a swept path analysis which models the capacity of the C292 to accommodate passing HGVs. The evidence before me indicates that the C292 width varies between 4.9m to 5.5m with a 4.2m pinch point. Whilst acknowledging that the C292 currently attracts HGV movements, including 2-way movements, in the absence of compelling evidence to the contrary, given the limited road width and the carriageway alignment, it hasn’t been satisfactorily demonstrated that the C292 has the capacity to safely accommodate passing HGVs. Indeed, numerous interested party comments reference minor collisions, vehicle damage, near misses and extensive damage to grass verges on the C292 caused by vehicles passing on the narrow carriageway. This casts further doubt on the capacity of the highway network to accommodate the development.

The proposal would see an increase in staffing numbers and is supported by a Travel Plan which includes measures to encourage staff travel to the site by sustainable means including by bike, e-bike and bus. The C292 is a narrow, unlit road which the Council and interested parties describe as being undulating and of a poor condition, with a speed and volume of traffic which is intimidating to users on bike. Whilst acknowledging that this route is used by cyclists, these conditions nonetheless indicate that there is the potential for conflict between cyclists and vehicles along this route.

The nearest bus stops serving [site address] are located on the A345 providing frequent connections to local settlements including Amesbury and Salisbury. There are no dedicated pedestrian facilities on the C292 and access to the bus stops would involve pedestrians walking along the grass verge and/ or carriageway of the C292 and crossing the A345. Given the lack of street lighting and the speeds and volumes of traffic involved this would likely pose a highway safety risk for users on foot, in particular during winter months and in low lighting.

Furthermore, access to the bus stop would involve crossing the A345, a busy road which lacks pedestrian crossing facilities. I observed during my site visit that there was a high volume of traffic on this route, and that there were limited gaps within the traffic to cross this road in the direction of the bus stop, in addition to which it is also necessary to navigate traffic exiting the petrol garage. These conditions indicate a difficulty accessing the bus stop and the potential for conflict between pedestrians and vehicles on the A345. Whilst this is a snapshot in time there is nothing in the evidence before me to indicate that these observations are atypical of the highway conditions on this route, indeed I note that numerous interested parties reference the difficulties in crossing this road to access the bus stop.

The above conditions indicate the potential for conflict between vehicles and pedestrians/ cyclists. The proposal would increase vehicular movements and seeks to encourage travel to the site by these modes. Given this, it would result in increased potential for these conflicts. Given the deficiencies identified, the lack of record of accidents on the C292 and A345 does not guarantee one would not happen in the future, in particular through planned additional use. The presence of other sites in locations which are undesirable in relation to accessibility and highway safety does not justify further development which would result in harm in this regard.

In support of the proposal, the appellant states that the intensification of the existing site could be undertaken without the need for planning permission, resulting in additional vehicular movements on the C292 and A345. However, the submission sets out that the existing site is heavily constrained by physical and structural limitations having reached its capacity, resulting in the need for a larger site. This indicates that this potential for intensification, and the vehicular movements associated with it, is merely theoretical. This reduces the weight to be afforded to this as a realistic fallback.

It has not been adequately demonstrated that the surrounding highway network has the capacity to safely accommodate the development without harm to highway safety. The proposal would therefore conflict with those aims of [name] (2015) (CS) policies 60, 61 and 62 which collectively seek to support and encourage the sustainable, safe and efficient movement of people and goods and which require that consideration has been given to the needs of all transport users, providing mitigating measures to offset any adverse impacts on the transport network. I also find conflict with the National Planning Policy Framework (the Framework), which seeks to ensure that development creates spaces that are safe, secure and attractive minimising the scope for conflicts between pedestrians, cyclists and vehicles. Location of development and accessibility

The appellant submits that a site location at [site address] is necessary in order to support trade and collaboration with Chemring. Approximately 35-40% of trade is with Chemring and face-to-face meetings between the companies to discuss technical and production issues take place regularly, with deliveries taking place several times per week. The appellant sets out that relocation outside of [site address] could risk the loss of existing highly-skilled staff, most of whom are based within 8 miles of the existing site.

The site is located in the open countryside in which core policy CP34 of the CS supports developments that are considered essential to the wider strategic interest of the economic development of Wiltshire, as determined by the Council, where specified criteria are met. The supporting text goes on to state that a number of target sectors have been identified to promote a move towards a higher-value economy, and proposals which support these sectors will be supported providing they meet the requirements of CS core policy 34. One identified target sector is advanced engineering and manufacturing.

CS core policy 34 doesn’t specify a size threshold or define what it considers to be ‘essential’ to the wider strategic interest of the economic development of Wiltshire. The Council state that the scale of development and employment retained/ generated would fail to be classed as essential to the wider strategic interest of the economic development of Wiltshire. The appellant submits that the proposal would facilitate increased productivity and employment in one of the specialist/ target sectors identified for growth and would support the move to a higher value economy. Given the size of the development, the appellant submits that the development’s implications in relation to the expansion of the appellant’s and connected businesses, and the highly skilled workforce which would continue to be employed at the site, the proposal should be considered essential to the wider strategic interests of the economic development of Wiltshire.

The appeal would facilitate the retention and expansion of the existing business, an increase in economic activity and the employment of 16 additional staff. These are undoubtably benefits of the proposal. However, by virtue of the scale of the development and the number of jobs created/ retained, these benefits fall far short of being essential to the wider strategic interest of the economic development of Wiltshire, and, whilst it is clear that there is a close relationship between the appellant and the defence contractors it supplies, in particular Chemring, that falls short of it providing an essential strategic role in the local economy. Accordingly, the proposal would not meet the exception to CS core policy CS34.

In support of the proposal the appellant refers to a number of employment allocations in the CS for sites of a similar or smaller size than the appeal site. However, this is indicative that the Council has sought to accommodate businesses of varying sizes through their employment allocations and it doesn’t necessarily follow that individually these sites are essential to the wider strategic interest of the economic development of Wiltshire.

The Council suggest that the development could be accommodated within any suitable site in the ‘[name] triangle’. In response to this the appellant has carried out a search of alternative sites within the area. These sites were discounted for a number of reasons. The appellant states that the capacity of the grid network to accommodate their power demands was a decisive factor in site selection and I heard during the hearing that the grid supplying 2 of the alternative sites2 is severely constrained such that significant infrastructure upgrades would be necessary to provide sufficient high voltage power to meet the appellant’s operational needs. The capacity of the network to meet the appellant’s power requirements is clearly a significant factor in the deliverability of these sites.

The appellant states that Solstice Park, Amesbury was discounted as the available units are not the right size to meet their operational needs. Clearly, a site which does not contain adequate floor space would fail to meet the appellant’s operational needs and thus cannot be considered a viable alternative. During the hearing I also heard that a site at Unit 1, [site address] Business Park3 was occupied and is not available. I have been presented with no compelling evidence that the [name] site is not progressing for the intended occupier or that this site is available. Whilst my attention is drawn to ‘[name] which is the subject of a current planning application4, I heard at the hearing that this site does not have planning permission and there is no compelling evidence before me that the scheme’s promoters would 2 [name], Salisbury and [address], Summerlug 3 Suggested during the course of the hearing by an [name] 4 PL/2026/01867 be willing to amend the current planning application to accommodate the appellant. Accordingly, this does not appear to be a viable or available alternative.

Drawing together the above, the appellant has conducted a thorough search of alternative sites, and I find the reasons for discounting these alternative sites to be compelling. The evidence before me indicates that there are no other available alternative sites which would meet the appellant’s operational needs. The absence of suitable alternative sites indicates that CS core policy 34 is failing to meet demands for new employment sites in rural areas. Given this, whilst I have found conflict with this policy insofar as it has not been demonstrated that the proposal would be essential to the wider strategic interest of the economic development of Wiltshire, I afford reduced weight to the conflicts with this policy.

A key component of the development plan and the Framework is the achievement of sustainable development, a consideration of which is the generation of job growth in locations which help reduce the reliance on the private car. Nonetheless, the Framework recognises that opportunities to maximise sustainable transport will vary between urban and rural areas and that decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations not well served by public transport, and that in these circumstances it will be important to ensure that development does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable, for example by improving the scope for access on foot, by cycling or public transport.

The appellant acknowledges that the site’s rural location offers limited attractiveness to non-car options and this is reflected in survey evidence of existing staff travel modes which indicates a reliance on the private vehicle. Measures to promote access to the site by sustainable modes of travel are set out in a travel plan which includes measures to encourage car sharing, use of low emission vehicles, cycling, bus travel, the provision of e-bikes and the potential for an electric minibus operated by the appellant. Nonetheless, the appellant acknowledges that the complexity of shift patterns (which operates on a 2-shift basis from 7:30am to 4pm and 1:30pm to midnight) and agreed adjustments to shift patterns to accommodate family requirements/childcare arrangements or overtime would likely limit the capacity for modal shift away from the private vehicle. This indicates that, notwithstanding the Travel Plan measures proposed, there would likely be a continued reliance on the private vehicle, and increases in trip generation associated with the proposed expansion.

The Framework recognises that opportunities to maximise sustainable transport will vary between urban and rural areas and I note that in the appeal decisions to which my attention has been drawn, Inspectors have found employment-generating developments in the open countryside dependent on the private vehicle to be acceptable5. Additionally, the appellant sets out that, given the shift pattern, even if the development was in a location with better public transport infrastructure, there would continue to be a reliance on the private vehicle. However, the Framework also establishes that in rural areas it is important to ensure that development does not have an unacceptable impact on local roads. Even accounting for the measures 5 APP/X1118/W/23/3317058, APP/Y3940/W/25/3373619 put forward to encourage a modal shift towards sustainable forms of travel, given the site’s remote location and the constraints posed by the shift pattern, the proposal is likely to result in additional vehicular movements on the highway network, the capacity of which to safely accommodate these movements has not been satisfactorily established. Given the local highway conditions, this results in the potential for increased highway conflicts. This differentiates the appeal proposal from the decisions to which my attention has been drawn in which there is no suggestion of the potential for increased highway conflicts.

I have found that the development would not be essential to the wider strategic interest of the economic development of Wiltshire. Whilst the absence of suitable alternative sites and the lack of capacity to accommodate employment-generating developments elsewhere reduces the weight to be afforded to the conflict with CS core policy 34, I have nonetheless identified that the site is located in a car-dependent location, and that, as the capacity of the highway network to safely accommodate these movements has not been satisfactorily established, I cannot be certain that the proposal would not result in the potential for increased highway conflicts. Consequently, the site is not in a suitable location for the proposal having regard to accessibility. Conflict therefore arises with those aims of CS policies CP1, CP2, CP60, CP61 and CP62 which seek to deliver employment land in sustainable locations, reduce the need to travel by private car and encourage the use of sustainable transport.

BNG is a mandatory requirement of Schedule 7A of the Town and Country Planning Act 1990 (as inserted by Schedule 14 of the Environment Act 2021) which sets out an objective for development to deliver at least a 10% increase in biodiversity value relative to the pre-development biodiversity value of the onsite habitat. A net increase of 26.97% habitat units would be provided through on-site landscaping. This would meet the requirements of Schedule 7A.

The appeal is supported by a UU which sets out that an index-linked payment of £5,815 will be made to the Council ‘towards its costs of monitoring compliance with conditions of the permission’. The Council set out that this financial contribution is necessary to cover the additional costs of monitoring the implementation of BNG plans. In support of this the Council refers to the Wiltshire Council BNG monitoring fees and charges note (the BNG note). The BNG note states that significant biodiversity gain will be secured by a planning condition or a legal agreement and that in order to cover the additional costs of monitoring the implementation of BNG plans, the Council has approved a monitoring fee for minor applications of £5,815.

BNG would be provided on-site and would comprise trees, native shrubs, ornamental shrubs, hedgerows, flowering lawn, wildflower grassland and tussocky grassland6. There is no compelling evidence before me that the 1.34 additional habitat and 4.60 additional hedgerow units are significant onsite habitat enhancements. The BNG does not involve significant enhancements in habitat conditions, the creation of a large number of biodiversity units, significant habitat creation or distinctiveness enhancement or habitat creation or enhancement which are significant in area relative to the size of the development. Given this I have not 6 BNG Report Landscape Strategy Plan Drawing ref 10976L.AO-LSP.005 [name] been presented with any compelling evidence that monitoring of the implementation of the BNG could not be satisfactorily achieved through condition. Thus, whilst I have considered the submitted UU, in these circumstances I am satisfied that the financial contribution towards monitoring is not necessary to render the development acceptable. In light of this, whilst the provision of BNG would be a benefit of the scheme, the sum that would be provided by the UU is not a matter which weighs in the development’s favour.

The development makes adequate provision for BNG. It would therefore comply with the requirements of the Environment Act 2021 and those aims of CS core policy 50 which seek to enhance biodiversity through the planning process.

I have had regard to the fact that the site is located within 3km of the World Heritage site of Stonehenge and Avebury (WHS) and have given consideration to any impact of the proposal on the setting or significance of this designated heritage asset. The WHS is 2 landscape areas which comprise a unique and dense concentration of outstanding prehistoric monuments internationally important for its complexes of outstanding prehistoric monuments. The significance of this heritage asset is derived from the WHS’s architectural, historic and landscape value.

The site is located on a prominent ridgeline, in which there is the potential for light spill with the potential to impact on the astronomical relationships of the monument and the landscape and the wider experience of the WHS. The appellant has submitted details of proposed lighting. The evidence before me indicates that, subject to conditions controlling the design, quantity and use of the lighting, the development would not cause significant light spill which would affect the dark skies setting of the WHS. Consequently, subject to the imposition of appropriate conditions, I have no reason to dispute the Council’s view that the proposal would not impact upon the setting of the WHS and, therefore, would not harm the significance of this designated heritage asset.

The site is also located in the vicinity of the [name] and Figsbury Ring Scheduled Ancient Monuments. [name] is a large multivallate hillfort dating to the [name] period. As a rare and well-preserved example of its class, its significance lies in its archaeological value and its importance in understanding the nature of social organisation within the [name] period. The surrounding open agricultural landscape contributes positively to the setting of [name]. The site lies on the ridgeline to the north of [name] which is broken up by the buildings at the [site address] Business Park and blocks of trees. The main parties agree that the development would not impact upon the setting and significance of [name]. Based on the evidence before me including my observations on site I see no reason to take a differing view.

[name] is a henge and slight univallate hillfort located on the summit of a prominent hill overlooking the valley of the [name] to the east of the site. Its significance appears to lie in its archaeological value. Given the separation between the site and [name] the site does not appear to contribute to the setting or significance of [name] and there is no suggestion that the proposal would impact on the setting or significance of this heritage asset.

I am satisfied that the proposal would not conflict with provisions within the Framework which seek to protect the significance of designated heritage assets.

The site is located in the [name] catchment of the River Avon Special Area of Conservation (SAC) in which developments have the potential to cause adverse effects through discharge of phosphorous in wastewater. The Council comment that, given the scale and nature of the development, there is no mechanism for adverse effect on the SAC. [name] have found harm in relation to the first 2 main issues it is not necessary in this instance to undertake an appropriate assessment to consider the effect on the SAC.

The Council raised no objections to the development’s landscape, heritage, ecological or arboricultural impacts, the internal road layout, proposed parking provision and arrangement, or the loss of agricultural land, and, based on the evidence before me, I see no reason to conclude otherwise. Nonetheless, compliance with the relevant development plan policies on these matters would be required in any case, therefore these matters weigh neutrally rather than in favour of the proposal.

The proposal would result in clear benefits to the local economy during the construction and occupation phases of the development. The development would allow an existing employer to continue operating in the area, serving the existing client base, expanding business through increased productivity and retaining and expanding the existing highly-skilled workforce. The proposal would expand one of the sectors identified by the Council in its move towards a higher-value economy and would enable the appellant to continue developing ties with local schools and colleges. These are real and tangible benefits which attract significant weight in the development’s favour.

The development would also result in the delivery of on-site BNG, and I note that the appellant seeks to deliver an energy-efficient building with a BREEAM ‘excellent’ rating which would be constructed using local building contractors and locally-sourced materials. The benefits in this regard attract moderate weight in the development’s favour.

On the other hand, I have found that the development’s effects on the highway network are unknown, casting doubt on whether the local highway network can satisfactorily accommodate the development safely. I have also found that the site’s location would result in a high dependence on the private vehicle with the potential for increased highway conflicts, contrary to CS policies CP1, CP2, CP60, CP61 and CP62. The conflict with these policies is determinative, such that the proposal would fail to accord with the development plan when considered as a whole. There are no material considerations, either individually or in combination, that indicate the appeal should be decided otherwise.

For the reasons set out above, I conclude the appeal should be dismissed.