We thought that’d be useful to share North Wraxall Parish Council’s objection comment for the development at Totts Lane, Colerne to assist other people commenting on this:
Here is our full comment:
1. Introduction and summary of concerns
North Wraxall Parish Council welcomes the principle of providing affordable housing to meet the needs of the next generation. However, new housing must be supported by appropriate infrastructure, and the impact on existing communities must be properly assessed before planning permission is granted.
The proposed affordable provision is also divided into:
- 10 affordable-rented homes;
- 7 affordable home-ownership homes, potentially Shared Ownership or First Homes.
The application proposes 17 affordable homes out of a maximum of 150—approximately 11%. Wiltshire Council should scrutinise the calculation and tenure mix as we feel this is a token amount. (Ref: Planning statement with appendices document.)
This is not an isolated application either as considerable development is also being discussed in the forthcoming local plan with respect to Azimghur Barracks. These applications must be considered together to create a comprehensive picture. It should be kept in mind that the combined numbers are far in excess of the current population of North Wraxall Parish and are substantially increasing the population of Colerne by at least a fifth.
NWPC wishes to raise significant concerns about the potential effects of the proposed development on the highway network, pedestrian and cyclist safety, groundwater, drainage and the wider natural environment.
NWPC has significant concerns about the Transport Assessment accompanying this application, particularly its treatment of the surrounding rural highway network and the proposed off-site highway improvements affecting North Wraxall parish.
NWPC is particularly concerned that it was not consulted about the proposed changes at Ford, despite Appendix 9.2 of the Transport Assessment specifically proposing traffic-calming measures in one of our villages. This is especially concerning because the parish is already discussing significant highway safety and traffic issues with Wiltshire Council.
The proposed development has implications beyond Colerne itself. Traffic will use routes through Ford and The Shoe, increasing pressure on the C151, the Fosseway and the surrounding narrow rural lanes. The Transport Assessment recognises these as alternative routes between Colerne and the A420, but NWPC considers that the assessment does not adequately establish the existing conditions, safety risks or cumulative consequences for the communities using them. Our local highways are severely constrained as it is; the combined impact of this and the MoD plans (at least 20% more traffic) seem unfeasible without significant highways alterations far beyond the seemingly insignificant proposed changes. (Transport Assessment PDF)
NWPC requests that Wiltshire Council address these concerns before determining the application.
2. Failure to consult North Wraxall Parish Council
Appendix 9.2 proposes traffic-calming measures at Ford, including:
- 30 mph roundels on The Dene;
- 40 mph roundels on red surfacing on either side of the junction with the A420;
- A 3.5-metre carriageway narrowing with priority for southwest-bound traffic; and
- Slow road markings on the approach to the ford.
These measures are described in the Transport Assessment as proposals under consideration, subject to further detailed discussions. Transport Assessment
Despite the direct implications for a village within North Wraxall parish, NWPC was not consulted about these proposals.
This is a serious omission. The Parish Council has local knowledge of the highway network, existing traffic patterns and recurring safety problems that should inform the design and assessment of any proposed changes.
NWPC is already in discussion with Wiltshire Council about significant concerns affecting Ford and The Shoe. The proposed development and its associated highway works should not be considered in isolation from these existing issues.
We request that Wiltshire Council formally consult NWPC on all proposed highway works affecting Ford, The Shoe and the surrounding parish road network before any measures are agreed or implemented.
The proposed traffic-calming scheme should be reviewed with the Parish Council, and the outcome of those discussions should be documented and considered as part of the planning decision.
3. Increased traffic through Ford and The Shoe
The Transport Assessment identifies two routes from Colerne to the A420 that are particularly relevant to North Wraxall parish:
- The Ford route: Bath Road through Ford, continuing along The Dene to the A420.
- The Shoe route: Via Bath Road and Fosse Way, with a connection to Doncombe Hill before reaching the A420.
The assessment describes sections of Bath Road and The Dene through Ford as narrowing to approximately 3–4 metres, with informal one-way working. It also describes Fosse Way as approximately 4–5 metres wide. Transport Assessment
These are rural roads with physical constraints that cannot be resolved simply by introducing traffic-calming signs or road markings.
NWPC is concerned that the development will increase traffic on both routes, adding pressure to roads where vehicles already encounter difficulties passing safely.
The applicant’s assessment concludes that the traffic increase will not have a material impact on the surrounding highway network. However, this conclusion depends on the accuracy of the traffic forecasts and distribution assumptions, and on whether the assessment adequately reflects conditions on the affected rural roads.
NWPC does not consider that the applicant has demonstrated sufficiently that these routes can safely accommodate additional traffic without unacceptable consequences for existing road users and residents.
The impact must be assessed across the entire affected network, rather than relying on the relatively small change predicted at individual junctions or during selected peak hours.
4. Concerns about traffic surveys and the reliability of the assessment
NWPC has concerns about the reliability and completeness of the traffic evidence used to support the application.
The Transport Assessment reports a one-week Automatic Traffic Count (ATC) survey undertaken on Bath Road between 15 and 21 January 2026. This survey measured traffic flows and speeds at the proposed site access. Transport Assessment
However, a count at this location does not, by itself, establish the volume and distribution of traffic on every rural route affected by the development.
In particular, NWPC is concerned that there is no traffic count data for Doncombe Lane or the Fosseway sufficient to establish the existing baseline and verify the applicant’s assumptions about the distribution of development traffic across the local network.
Without representative data for these roads, it is difficult to establish:
- Existing traffic volumes and the frequency of vehicles meeting on narrow sections;
- The likely increase in traffic through The Shoe and along the Fosseway;
- Whether the existing carriageways and passing places can accommodate additional movements safely;
- The implications for pedestrians and other vulnerable road users; and
- The cumulative impact of the development alongside existing traffic and other local pressures.
NWPC, therefore, questions whether the traffic modelling and distribution assumptions provide a sufficiently robust basis for concluding that the development would have no material impact.
The Parish Council will supplement this representation with traffic-volume statistics collected using its Speed Indicator Device (SID) in Ford. These figures will provide additional local evidence about actual traffic volumes and should be considered alongside the applicant’s surveys. Unfortunately, we will not be able to supply the data before the application deadline as we have not had notice of the application.
We request that Wiltshire Council require the applicant to provide further traffic data and a transparent explanation of how traffic has been distributed across the Ford and The Shoe routes, including Doncombe Lane and the Fosseway.
5. Highway safety at Ford
Ford already presents significant highway safety concerns, which NWPC has raised with Wiltshire Council.
An important issue is the interaction between additional traffic, the narrow road layout and the ford itself. Flooding can occur at Ford, making the usual route impassable or unsuitable and necessitating additional traffic using the Fosseway. Black ice is a significant issue by the pub and where the A420 crosses the By Brook River..
This means that the distribution of traffic between the two routes cannot necessarily be treated as fixed. Conditions at Ford can redirect traffic onto alternative rural roads, potentially increasing pressure on the Fosseway and The Shoe precisely when conditions elsewhere are already difficult.
The assessment should therefore consider not only normal operating conditions but also the consequences of flooding and other circumstances that alter the distribution of traffic.
The proposed traffic-calming measures at Ford do not, in themselves, demonstrate that these wider safety issues have been adequately addressed.
NWPC also wishes to highlight the recurring minor collisions and vehicle impacts experienced at Ford and The Shoe. Wiltshire Council’s official accident records do not capture the full extent of these incidents.
The Parish Council understands that Wiltshire Council’s highway records depend substantially on incidents being reported to the police, while police attendance may not occur where there is no injury and the highway is not blocked. Consequently, the absence of a recorded personal-injury accident does not necessarily mean that a road or junction is operating safely.
NWPC has already provided Wiltshire Council with evidence of recurring minor collisions and vehicle impacts at Ford and The Shoe. This evidence should be considered alongside formal accident statistics when assessing the safety of the proposed development.
We request that the highway authority review the evidence already supplied by NWPC and assess the implications of additional traffic using these routes.
6. Doncombe Bottom bridge and the Fosseway
NWPC has particular concerns about the safety of the Fosseway and the route through Doncombe Bottom.
The bridge at Doncombe Bottom is frequently struck by vehicles because of the tight bend. This is a known local concern and demonstrates the limitations of the existing road geometry.
Additional traffic could increase the frequency of vehicle conflicts and impacts at this location. The risks may be compounded when vehicles meet on narrow sections of road or when drivers need to manoeuvre to negotiate the bend and bridge.
These concerns are especially relevant if flooding at Ford diverts traffic onto the Fosseway.
The Transport Assessment describes Fosse Way as a narrow rural road and identifies it as one of the principal routes connecting Colerne to the A420.
However, NWPC considers that the assessment does not adequately demonstrate how the existing constraints at Doncombe Bottom will be affected by the proposed development.
We request that Wiltshire Council require a specific safety assessment of the bridge, the bend and the adjoining approaches. This should consider vehicle types, passing movements, visibility, existing damage incidents and the potential for increased traffic during periods when Ford is affected by flooding.
Any necessary mitigation must be identified and secured before permission is granted, rather than left as an unresolved issue following approval.
7. Pedestrian safety and public rights of way
The lack of suitable pedestrian infrastructure is a major concern.
There is no pavement through Ford, despite the presence of two National walking routes along the road:
- The Macmillan Way;
- The Cross Cotswold Pathway.
Walkers using these routes share the highway with motor vehicles. An increase in traffic would create additional conflict between vehicles and pedestrians, particularly where the carriageway is narrow and there is limited opportunity to step clear of passing traffic.
The existing situation is not satisfactory, and the proposed development would add to the pressure on this route unless appropriate mitigation is provided.
Pavements are also limited at The Shoe. The absence of continuous, safe pedestrian provision makes it difficult to separate people walking from motor traffic.
NWPC considers that the applicant must demonstrate how pedestrian safety will be protected along the affected routes, taking account of both everyday journeys and recreational walking.
The Transport Assessment proposes new pedestrian facilities close to the development site and traffic-calming measures at Ford. However, improvements near the site cannot be assumed to resolve pedestrian safety issues elsewhere on the rural network.
We request that Wiltshire Council require a comprehensive assessment of pedestrian safety through Ford and The Shoe, including the implications for the Macmillan Way and Cross Cotswold Pathway.
Where additional traffic is expected, appropriate infrastructure must be provided to protect pedestrians. This should include consideration of whether safe footways or other suitable pedestrian measures can be delivered and maintained.
8. Passing places and the suitability of the rural road network
The existing width and alignment of the rural roads raise further concerns.
The Transport Assessment describes Fosse Way as approximately 4–5 metres wide and Doncombe Lane as narrowing to around 3 metres where it becomes Doncombe Hill. Passing places are limited on Doncombe Hill.
These constraints are important because additional traffic does not simply increase the number of vehicles using the roads. It also increases the likelihood of vehicles meeting at narrow points, requiring one vehicle to reverse or wait while another passes. Indeed we have issues currently with enforcing heavy/large vehicle restrictions on this road and have previously tried to engage Wiltshire Council on this matter.
NWPC considers that appropriately engineered passing places would need to be assessed and, where necessary, provided to address the increased traffic.
Such works must be designed around the actual topography, visibility, road geometry and constraints of the rural environment. They should not be assumed feasible without detailed investigation.
The assessment should also establish whether any proposed passing places would be safe for pedestrians, avoid creating new hazards at bends or junctions, and be deliverable without unacceptable environmental damage.
NWPC requests that Wiltshire Council require a detailed review of the capacity and safety of the Fosseway and Doncombe Lane, including the need for engineered passing places and any other necessary improvements.
9. Wider infrastructure, geological and natural environment concerns
Although highways and footpaths are NWPC’s principal concerns, the consequences of the development extend beyond the carriageway.
The surrounding rural network forms part of a wider landscape and natural environment. Any road widening, passing places, changes to drainage or other highway engineering could affect local habitats, landscape character and the physical environment.
The potential for flooding at Ford is also relevant to the resilience of the wider road network. If flooding regularly changes which route vehicles use, this needs to be considered when assessing the development’s effects on both routes.
NWPC requests that any proposed highway works be assessed for their implications for:
- Surface-water drainage and flood risk;
- Local geology and ground conditions;
- Habitats, wildlife and the wider natural environment;
- Landscape character and the rural setting;
- Existing public rights of way and recreational walking routes; and
- The feasibility and environmental consequences of road widening and passing places.
These issues should be considered alongside highway safety, rather than treated as separate matters that can be addressed only after the principle of development has been established.
10. Affordable housing must be supported by adequate infrastructure
NWPC recognises the need for affordable homes and the importance of providing opportunities for younger people to remain in their local communities.
However, the delivery of housing must be accompanied by infrastructure that is appropriate to the location and scale of the development.
The Transport Assessment concludes that the proposed development would not have a material impact on the safety or operation of the local highway network.
NWPC does not consider that this conclusion has been sufficiently demonstrated in relation to the roads affecting North Wraxall parish.
In particular, the assessment must take proper account of:
- The existing highway safety concerns at Ford and The Shoe;
- The lack of a pavement through Ford and limited pedestrian infrastructure at The Shoe;
- The use of these routes by walkers on two National walking routes;
- Flooding at Ford and the resulting diversion of traffic onto alternative roads;
- The recurring vehicle impacts at Doncombe Bottom bridge;
- The limited width and alignment of the Fosseway and Doncombe Lane;
- The absence of sufficient traffic-count data to verify the assumptions for these routes; and
- The need for appropriately engineered passing places and other highway improvements.
These are not minor details. They are fundamental to whether the surrounding road network can accommodate the development safely.
11. Groundwater, contamination and private water supplies
NWPC is concerned about the potential effects of developing the former airfield and industrial site on groundwater quality.
The Planning Statement acknowledges that the site lies above a Principal Aquifer and identifies potential contamination associated with its historic airfield use and current industrial use. It identifies the potential for contaminants to migrate into groundwater and recommends further intrusive investigation.
The Environment Agency has also identified a risk that contamination from the former airfield could be mobilised during construction or through surface-water drainage. This requires particular attention because groundwater may support private water supplies in the surrounding area.
NWPC considers that the potential for contamination to affect the aquifer and any connected private water supplies must be properly investigated and addressed. The assessment should identify relevant groundwater pathways and receptors, establish the nature and extent of any contamination, and demonstrate that construction, drainage and the completed development would not cause unacceptable deterioration in groundwater quality.
We ask Wiltshire Council to obtain the necessary advice from the Environment Agency and other relevant bodies and to ensure that appropriate investigations and protective measures are established before development proceeds. Any required monitoring, contingency arrangements and long-term responsibilities should be clearly defined and secured.
The fact that further investigation is proposed at a later design stage should not leave material risks unresolved when the planning application is determined.
12. Cycling and active travel
The application promotes active travel and proposes pedestrian and public-rights-of-way connections. However, the wider effects of increased traffic on existing cycling routes also need to be addressed.
Bath Road and the Bannerdown Road connection are used by cyclists travelling between Thickwood, Ford and Bath. These roads currently offer a practical rural cycling route, in part because of their relatively low traffic levels. An increase in motor traffic could reduce the safety and attractiveness of this route, discouraging cycling and undermining the stated objective of supporting active travel.
The Transport Assessment indicates that approximately 240 car-parking spaces would be required based on local car-ownership levels. This reinforces the need to assess the likely level of car use and the consequences for the surrounding network, rather than assuming that proposed walking and cycling links within or near the site will offset the effects of additional vehicle movements.
NWPC requests that the applicant and Wiltshire Council assess the effects of the development on cycling safety along Bath Road and the Bannerdown Road connection, as well as on other routes used by cyclists from the surrounding villages. Any necessary mitigation should be identified and secured.
13. Requests to Wiltshire Council
North Wraxall Parish Council requests that Wiltshire Council:
- Formally consult NWPC on the proposed traffic-calming measures at Ford in Appendix 9.2 and on any other highway changes affecting North Wraxall parish.
- Require additional traffic evidence for the Fosseway and Doncombe Lane, with transparent assumptions and analysis of the expected traffic distribution between Ford and The Shoe.
- Consider the SID data to be supplied by NWPC, alongside the evidence already provided to Wiltshire Council concerning recurring minor collisions and vehicle impacts.
- Require a highway safety assessment of Ford, taking account of flooding, the ford itself, narrow carriageways and the consequences of additional traffic.
- Require a specific safety assessment of Doncombe Bottom bridge, including the tight bend, recurring vehicle impacts and the implications of additional traffic.
- Address pedestrian safety, including the absence of a pavement through Ford, limited pavements at The Shoe and the use of these roads by the Macmillan Way and Cross Cotswold Pathway.
- Assess the need for engineered passing places and other necessary highway improvements along the Fosseway and Doncombe Lane.
- Assess the wider environmental implications of highway works, including drainage, flooding, geology, habitats and landscape.
- Ensure that necessary mitigation is deliverable and secured through the planning process, with responsibilities, funding and timescales clearly established.
- Consider the cumulative impact of the development on the whole rural highway network, rather than relying solely on predicted changes at individual junctions or during selected peak hours.
- Require adequate groundwater and contamination investigations, including assessment of potential effects on the Principal Aquifer and any potentially affected private water supplies, with appropriate protective measures and monitoring secured.
- Assess the impact on cycling safety, including Bath Road and the Bannerdown Road connection, and identify any necessary mitigation.
14. Conclusion
North Wraxall Parish Council supports the provision of affordable housing for the next generation, but this application only provides a token effort as there is not adequate provision particularly for young first time buyers. Additonally, this must not come at the expense of highway safety or the wellbeing of existing rural communities.
The proposed development has implications for Ford, The Shoe and the surrounding road network. These include additional traffic on narrow rural roads, inadequate pedestrian infrastructure, recurring vehicle impacts, flooding-related traffic diversions and the constraints imposed by Doncombe Bottom bridge.
NWPC is particularly concerned that it was not consulted about the proposed changes at Ford, despite Appendix 9.2 specifically addressing traffic-calming measures in one of the parish’s villages and despite the Parish Council already raising significant concerns with Wiltshire Council. The proposed changes seem inconsequential when considering the increase in traffic the combined proposals will bring about.
The Parish Council also questions whether the traffic assessment adequately reflects actual conditions on the Fosseway and Doncombe Lane, given the absence of sufficient traffic-count data for these routes. The forthcoming SID statistics and existing evidence of minor collisions will help inform this assessment. (Evidence has been sent regularly to Kirsty Rose but mainly concerns larger incidents but there is constantly debris from accidents which residents clean-up.)
NWPC requests that the application is not determined until the highway authority has properly assessed these concerns, consulted the Parish Council and established what mitigation is necessary, feasible and deliverable. If the outstanding issues cannot be satisfactorily resolved, the application should be refused on highway safety grounds.
The principle of affordable housing is supported, but safe and appropriate infrastructure must be a prerequisite for development, not an afterthought.