Wallingford Neighbourhood Planанаpublicity Period Response 1

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Wallingford Neighbourhood Plan publicity period Response 1

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Respondent Number: 1 Respondent ID: 143470675 Date Started: 19/06/2020 09:47:15 Date Ended: 19/06/2020 09:54:09 Time Taken: 6 minutes 53 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

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Your comments

Q2. You can provide your comments on the Wallingford Neighbourhood Plan below. When commenting, you should bear in mind that the examiner will mainly assess the plan against the 'basic conditions', which are set out in the Basic Conditions Statement If you are commenting on a specific section or a supporting document, please make this clear. After this publicity period consultation, the opportunity for further comments will be only at the request of the examiner. If you wish to provide evidence and any supporting documents to support or justify your comments, there is a facility to upload your documents below.

Thank you for consulting the Environment Agency on the Wallingford Draft Neighbourhood Plan.

We aim to reduce flood risk, while protecting and enhancing the water environment. We have had to focus our detailed engagement to those areas where the environmental risks are greatest.

Based on the environmental constraints within the area, we have no detailed comments to make in relation to your Plan at this stage. However together with Natural England, English Heritage and Forestry Commission we have published joint advice on neighbourhood planning. This sets out sources of environmental information and ideas on incorporating the environment into plans. This is available at:

https://webarchive.nationalarchives.gov.uk/20140328154245/http://cdn.environmentagency.gov.uk/LIT_6524_7da381.pdf

We are pleased to see that the proposed allocations have been directed to the areas at the lowest probability of flooding and that they are all located within Flood Zone 1.

The Local Authority will be able to advise if there are areas at risk from surface water flood risk (including groundwater and sewerage flood risk) in your neighbourhood plan area. The Surface Water Management Plan will contain recommendations and actions about how such sites can help reduce the risk of flooding. This may be useful when developing policies or guidance for particular sites.

Q4. If appropriate, you can set out what change(s) you consider necessary to make the plan able to proceed below. It would be helpful if you are able to put forward your suggested revised wording of any policy or text.Please be as precise as possible.If you wish to provide evidence and any supporting documents to support or justify your comments, there is a facility to upload your documents below.

None.

Public examination Q6. Most neighbourhood plans are examined without the need for a public hearing. If you think the neighbourhood plan requires a public hearing, you can state this below, but the examiner will make the final decision. Please indicate below whether you think there should be a public hearing on the Wallingford Neighbourhood Plan:

No, I do not request a public examination

Your details and future contact preferences

Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title

Name Samuel Pocock

Job title (if relevant) Planning Advisor

Organisation (if relevant)

Organisation representing (if relevant) Environment Agency

Address line 1 Red Kite House, Howbery Park

Address line 2

Address line 3

Postal town

Postcode OX10 8BD

Telephone number

Email address Planning_THM@environmentagency.gov.uk Response 2

Respondent Details

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Respondent Number: 2 Respondent ID: 143921385 Date Started: 27/06/2020 11:44:53 Date Ended: 27/06/2020 12:03:20 Time Taken: 18 minutes 26 seconds Translation: English IP Address: Country: United Kingdom

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Factual inaccuracy in Chapter 5 Natural Environment, Map 6 (p 67). The names of the two AONBs in the key are the wrong way round the names do not match the corresponding colours/areas.

Reference error in Appendix C (p 147). Paragraph C.1 refers to Table B1 instead of Table C1. Paragraph C.2 refers to Table B2 instead of Table C2.

Unnecessary duplication in Appendix C (p 148). Paragraph C.3 is just a copy of paragraph C.2 with identical tables. If paragraph C.3 is supposed to relate to working age population then Table C3 should reflect this moredetailed breakdown of 1665 yearolds.

Unnecessary duplication in Appendix C (p 149). Paragraph C.5 is just a copy of paragraph C.1 with identical tables.

Correct key in Chapter 5 Natural Environment, Map 6 (p 67) so the names of the two AONBs match the corresponding colours/areas.

Correct reference errors in Appendix C (p 147) using correct Table names.

Either delete paragraph C.3 or amend Table C3 to reflect the moredetailed breakdown of 1665 yearolds.

Delete paragraph C.5.

Public examination

Q6. Most neighbourhood plans are examined without the need for a public hearing. If you think the neighbourhood plan requires a public hearing, you can state this below, but the examiner will make the final decision. Please indicate below whether you think there should be a public hearing on the Wallingford Neighbourhood Plan:

No, I do not request a public examination Your details and future contact preferences

Title Mr

Name Richard Bakesef

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Email address Response 3

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Respondent Number: 3 Respondent ID: 144344512 Date Started: 03/07/2020 18:23:27 Date Ended: 03/07/2020 18:25:15 Time Taken: 1 minute 47 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Individual

Your comments

It seems comprehensive and addresses local concerns.

Public examination

Don't know

Your details and future contact preferences Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title

Name Anna Hindle

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Email address Response 4

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Respondent Number: 4 Respondent ID: 146134129 Date Started: 05/08/2020 18:48:10 Date Ended: 06/08/2020 15:32:03 Time Taken: 20 hours 43 minutes 52 seconds Translation: English IP Address: Country: United Kingdom

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I would like to propose that the plan includes the following proposal: That the area of Market Place, St Martins and St Marys Street be closed to nonessential vehicle traffic permanently.

I note that the plan makes several references to the reduction of traffic through the centre of Wallingford a selection of these are referenced below:

CHAPTER 8 MOVEMENT AND CONNECTIVITY 8.1 Vision and Objectives • The town centre will be more pedestrianfocused, with reduced vehicular traffic, so that people can relax and enjoy visiting our shops and restaurants. • Wallingford will have a safe and attractive environment for pedestrians and cyclists with a low speed limit of 20 mph throughout.

Chapter 8 also refers to the 'vision' which includes: • The town centre will be more pedestrianfocused, with reduced vehicular traffic, so that people can relax and enjoy visiting our shops and restaurants. • Wallingford will have a safe and attractive environment for pedestrians and cyclists with a low speed limit of 20 mph throughout. OBJECTIVES • MC01: Reduce congestion and minimise vehicular traffic travelling through the town.

Q3. You can upload supporting evidence here.

File: Parking 11 Elderly Lady 1.JPG File: Parking 12 Elderly Lady 2.JPG File: Parking 1.JPG File: Parking 3.JPG File: Parking 16.JPG

I would like to propose that the plan includes the following proposal: That the area of Market Place, St Martins and St Marys Street be closed to nonessential traffic permanently. Reasons • Parking is out of control with no Traffic enforcement at all. St Martins street is regularly difficult to navigate with parked cars on the footpath. Se photos above • There are plenty of car parks for the size of the town but their use should be encouraged more, closing the town centre would promote this • Pollution is a big issue in the 2 narrow streets with buildings either side. This issue is now high on political agendas and the closing of small town centres to traffic is gaining traction. Wantage had a very successful trial of this in June 20 • Businesses will not lose custom. They said this would happen if there was a bypass built. They were wrong. The bi pass is under utilized because drivers travel through the centre of Wallingford like a ‘Rat Run’. • It would take minimal effort and cost to close the area in question, to traffic. This happens without issue on occasions such are Carnival and Bunk Fest etc. Busses using the centre of town is just ridiculous. There is a perfect area for busses by the Library on High Street.

Public examination

No, I do not request a public examination

Your details and future contact preferences

Title Mr

Name Graham Fryer

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Email address Response 5

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Respondent Number: 5 Respondent ID: 146206291 Date Started: 07/08/2020 07:20:48 Date Ended: 07/08/2020 07:33:48 Time Taken: 13 minutes Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Individual

Your comments

I feel that the plan has achieved a reasonable compromise and that it is important that it is adopted.

Public examination

Don't know

Title

Name Anna Hindle

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Address line 1

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Address line 3

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Email address Response 6

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Respondent Number: 6 Respondent ID: 146325514 Date Started: 10/08/2020 15:52:05 Date Ended: 10/08/2020 15:56:03 Time Taken: 3 minutes 57 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

See attached comments.

Q3. You can upload supporting evidence here.

File: 20200810 SODC Reg 16 Wallingford.pdf

See attached comments.

Public examination

Don't know

Your details and future contact preferences

Planning services HEAD OF SERVICE: ADRIAN DUFFIELD

Contact officer: Robyn Tobutt [email protected] Tel: 01235 422600

19 August 2020 Textphone users add 18001 before you dial Wallingford Neighbourhood Development Plan – Comments under Regulation 16 of the Neighbourhood Planning (General) Regulations 2012 (As Amended)

South Oxfordshire District Council has worked to support Wallingford Town Council in the preparation of their neighbourhood plan and compliments them on a very thoughtful, comprehensive and well produced plan review. In order to fulfil our duty to guide and assist, required by paragraph 3 of Schedule 4B to the Town and Country Planning Act 1990 (as amended), the council commented on the emerging Wallingford Neighbourhood Development Plan (NDP) during the pre- submission consultation. We note that the qualifying body has taken some the council’s advice on board and addressed a number of the concerns previously raised during the Regulation 14 consultation. We are committed to helping this plan succeed. To achieve this, we offer constructive comments on issues that are considered to require further consideration. To communicate these in a simple and positive manner; we produced a table containing an identification number for each comment, a description of the relevant section/policy of the NDP, our comments and, where possible, a recommendation. Our comments at this stage are merely a constructive contribution to the process and should not be interpreted as the Council’s formal view on whether the draft plan meets the basic conditions.

Robyn Tobutt

Robyn Tobutt Planning Policy Officer (Neighbourhood)

Ref. Section/Policy Comment/Recommendation General Comments

The emerging South Oxfordshire Local Plan 2034 is currently at examination. Whilst neighbourhood plans are tested against the adopted development plan for the district (South Oxfordshire Core Strategy 2012, Saved policies from the South Oxfordshire Local Plan 2011 and Oxford County Council Mineral and Waste Plans), the evidence and reasoning of our emerging local plan is relevant to the consideration of whether a neighbourhood plan meets the basic conditions.

During the examination the Inspector wrote to the Council setting out questions and comments. In responding to the Inspector’s questions the Council proposed modifications to some policies in the submitted Local Plan. The Inspectors questions and the Council’s responses can be found here. In correspondence with the Council, IC3 and IC6 in particular, the Inspector indicated the proposed changes to policies which appeared acceptable and could be included in the draft schedule of main modifications. The current draft Schedule of Proposed Main Modification can be found in the examination library, link here, this was last updated on 6 July 2020.

The hearing sessions on the examination of the emerging Local Plan have provisionally concluded. During the hearing sessions the Inspector invited the council to consider further modifications to policies in the submitted Local Plan. The council is currently working on the drafting of these modifications and will submit them in advance of the Inspector providing a preliminary note. If sound subject to modifications, Modifications consultation will need to take place for six weeks.

The examination remains open until the Inspector has completed his report into the soundness of the proposed Local Plan. Before making a recommendation and publishing his final report, the Inspector can: request more information; ask for more work to be carried out; or require further hearing sessions to take place.

National Planning Practice Guidance highlights the importance of minimising any conflicts between policies in neighbourhood plans and those in the emerging local plan (Paragraph 009 Reference ID: 41-009- 20190509). Some of the proposed main modifications to the emerging local plan may be relevant to the examination of this Neighbourhood Plan. We have endeavoured to highlight where this is applicable in our comments to specific policies, acknowledging that there may be further modifications prior to the modifications consultation taking place.

More Generally, it should be noted that references to the emerging ‘South Oxfordshire Local Plan 2034’, should be amended to ‘South Oxfordshire Ref. Section/Policy Comment/Recommendation Local Plan 2035’ as this has been indicated by the Inspector to be a necessary modification to the local plan.

Page 10 – Paragraph We recommend that this paragraph is updated to 1.1.6 reflect most up to date position regarding emerging Local Plan. The Holding Direction is no longer in place and the emerging Local Plan is at examination. Page 15 – The Plan’s The final stages of this diagram are not factually Journey and Final correct. The Plan was submitted in February. Stages The stages suggest that a referendum takes place twice, this is not the case and the text should be amended to reflect this. Page 24 – Policy WS1: In line with our Regulation 14 comments, a The Local Strategy for neighbourhood plan should support the delivery Wallingford of strategic policies set out in the development plan. The Core Strategy 2012 sets out a strategy for Wallingford in Policy CSWAL1. The emerging Local Plan 2034 also contains a strategy for Wallingford in Policy WAL1. The NPPF sets out in paragraph 18 that:

‘Policies to address non-strategic matters should be included in local plans that contain both strategic and non-strategic policies, and/or in local or neighbourhood plans that contain just non-strategic policies.’

The Cholsey neighbourhood plan proposed a similar strategy, in the examiner’s report the examiner states (available here):

‘The approach taken is very sound. I can see that it consolidates and expands the Vision set out in Section 2 of the Plan. It is precisely the type of strategic statement that is properly found in neighbourhood plans. However, it is a strategic statement rather than a policy.

Furthermore the Strategy is shown in light grey tonal filling in the same way as the policies in the remainder of the Plan. This is potentially confusing to the lay reader. As such I recommend that the grey tonal shading is removed from the text box.’

In line with the examiner’s recommendation on the Cholsey neighbourhood plan we support the inclusion of a strategic statement. However, it is not a policy, so the word ‘policy’ should be Ref. Section/Policy Comment/Recommendation deleted, and it should be presented differently to the other policies in the plan. Page 27 – Para 2.4.9 Amend the supporting text in line with the changes made to WS1.

Suggested modification, delete ‘policy’. Page 28 – Para 2.4.18 Instead of saying ‘completions and commitments for the period to 2034 to 1,431’, to more accurately reflect the most up to date position, we suggest:

‘This brings the total completions and commitments as of 31 March 2019 to 1,413.’ Page 28 – Para 2.4.19 Update footnote 6 in line with the proposed updates to the emerging Local Plan and table 5d, which is that total completions and commitments as of 31 March 2019 is 1,413.

Please note that the growth requirement for the towns was subject to discussion at the emerging South Oxfordshire Local Plan examination. The Inspector asked the Council to consider modifications relating to this matter. The proposed main modifications will clarify what the Inspector considers to be the necessary modifications to make the policy sound. We can present the examiner with proposed modifications in due course. Page 30 – Policy WS2: WS2.1 The Land Allocation for For clarity, replace ‘shall’ with ‘should’. Housing in Wallingford Page 31 – Footnote 10 Remove footnote 10 as appears to be included by error. Page 31 – Policy WS3: The emerging Local Plan includes a density Housing Density policy, STRAT5, which is currently at examination. The neighbourhood plan policy as drafted would not be in general conformity with the emerging South Oxfordshire Local Plan.

Density requirements was subject to discussion at the emerging South Oxfordshire Local Plan examination. The Inspector asked the Council to consider modifications relating to this matter. The proposed main modifications will clarify what the Inspector considers to be the necessary modifications to make the policy sound. We can present the examiner with proposed modifications in due course. Ref. Section/Policy Comment/Recommendation Page 32 – Policy WS4: WS4.1(a) Development Within the In line with our previous comments at Regulation Built-up Area 14, this point seeks to group together a number of issues which are dealt with differently in national and local policy. Whilst additional text referring to policies CF1 and CF3 has been added, this has not provided the necessary clarity required by national guidance. It is not clear which policies are being referred to as the Wallingford Neighbourhood Plan, Local Plan 2011 and the emerging Local Plan 2034, have policies referred to as CF1 and CF3. We would recommend that instead of referring to other policies, the policy is amended so that the flexibility is incorporated into the policy.

Saved Policy H4 in the Local Plan 2011 contains a similar criterion addressing open spaces which we recommend is used:

‘the loss of an existing important open space of public, environmental or ecological value.’

WS4.1(d) This point refers to the historic character of Wallingford and duplicate matters which are dealt with in more detail in Policy HA1 of the Neighbourhood Plan. Paragraph 16 (f) of the NPPF sets out that policies should avoid duplication. Page 38 – Footnote 11 Appears as if this is an incorrect reference to the relevant sections of the NPPF, we suggest this reference is removed. Page 41 – Policy HD4: We welcome the inclusion of a self-build policy, Self Build however as currently worded the policy lacks clarity. The South Oxfordshire emerging Local Plan sets out in Policy H12 that ‘Neighbourhood Development Plans should consider the local need for this type of development and where appropriate identify specific sites to allocate for self-build and custom housing.’ The Wallingford Neighbourhood Plan does not seek to make any specific allocations relating to self-build and custom housing and the plan does not appear to give regard to local need. We therefore recommend that ‘where local need can be demonstrated’ is added to the policy text. Ref. Section/Policy Comment/Recommendation Page 41 – Policy HD5: HD5.2 Avoidance of Light We recommend ‘must’ is replaced with ‘should’, Pollution so that the policy has flexibility to appropriately deal with planning applications. Page 46 – Paragraph Factual correction – correct ‘Heritage England’ 4.2.7 with ‘Historic England’. Page 57 – Policy HA1: HA1.1 This Historic Our comments from our Conservation and Environment Design Team from the Regulation 14 submission still apply:

The phrase ‘The town’s historic environment shall be protected, conserved and enhanced.’ Suggests that all three actions will be achieved. We cannot secure enhancement of all heritage assets but we can seek to preserve/conserve/protect from harm. Suggest change from ‘and’ to ‘or’ in this phrase.

HA1.2(c) This criterion relates to pre-application work, which is an administrative issue. There is no requirement to consult the local community on SODC’s pre-application advice service, the service is discretionary. Historic England do not wish to be consulted on SODC pre-application work and have their own pre-application service. We therefore suggest that this text is removed from the policy. Page 59 – Policy: HA4: We have concerns with this policy in line with our Enabling development Regulation 14 comments, this policy is overly supporting Heritage at restrictive and does not have regard to the Risk NPPF, specifically paragraph 56, which states:

‘Planning obligations must only be sought where they meet all of the following tests: a) Necessary to make the development acceptable in planning terms; b) Directly related to the development; and c) Fairly and reasonably related in scale and kind to the development.’

We do not consider that this policy meets these tests. Page 59 – Paragraph These paragraphs support Policy HA4, which as 4.10.10 we have set out above, do not have regard to the tests set out in the NPPF in paragraph 56. Ref. Section/Policy Comment/Recommendation Page 68 – Policy EV1: Ev1.1(a3) New Green Spaces and This section of the policy requires developments Green Corridors to deliver measurable net gains in biodiversity which is consistent with both the Core Strategy and emerging Local Plan 2034 however, it then goes on to state that the gain should be delivered 'within the development area'. In practice delivering net gain solely within the development area is very difficult and many developments only partially achieve this with the remainder being delivered off site. We would recommend that 'within the development area' is deleted from the policy.

The policy then goes on to provide guidance on the type of measure to be used "using the most up-to-date measure for Oxfordshire (e.g. Thames Valley Environment Record Centre)".

We no longer allow the use of the TVERC calculator as there is now a Defra metric which has superseded it. We would therefore amend this text to read:

‘using the most up-to-date metric’ Page 69 – Paragraph The first sentence of this paragraph appears 5.4.2 incomplete. We suggest it is reworded as follows:

‘Within the context of the natural environment light pollution or excessive use of artificial light is inappropriate.’ Page 77 – Policy EE2: Please note that during the examination the Safeguarding Existing Council updated the Local Plan’s Employment Local Employment Sites Land Allocations, which has clarified the for Class B Uses quantum of employment development and refers to the employment land requirement as a minimum. These are set out in document reference PSD60 which has been sent to the Inspector, and is available here.

In addition this policy does not have regard to the recent changes to the Use Class Order announced by the Government.

During the course of the South Oxfordshire Local Plan examination, the Council produced a note on this for the Inspector (available here). In response the Inspector responded with some Ref. Section/Policy Comment/Recommendation additional requirements (available here). The proposed main modifications will clarify what the Inspector considers to be the necessary modifications to make the policy sound.

As summarised in the above note the changes will give certain businesses greater freedom to adapt to changing circumstances and to respond more quickly to the needs of their communities. The changes bring together A1(shops), A2 (financial and professional services), A3 (restaurants and cafes) and B1 (business) as well as parts of classes D1 (non-residential institutions) and D2 (assembly and leisure) into one single new E Use Class ‘Commercial, Business and Service’. From 1 September 2020 changes of use between the different types of uses listed in the new Class E will not constitute development and so will not require planning permission. That means (for example) that retail units can be converted into offices (and vice versa) without the need for permission.

The policy therefore should not say that the change of use to retail uses will be resisted and we suggest that this is removed from the policy. Page 78 – Policy EE3: EE3.1(b) Resist Loss of In line with our Regulation 14 comments, the Employment Space and NPPG sets out that policies in neighbourhood Uses plans should be concise and precise. This point could be re-worded to make it more concise, whilst achieving the same outcome. We recommend the following wording:

‘it is evidenced that there is no market interest in the site following one year of active and effective marketing’.

During the course of the emerging South Oxfordshire Local Plan examination, main modifications have been proposed to EMP3: Retention of Employment Land. These proposed modifications can be currently viewed under reference 42 of document CSD13 dated 6 July 2020 (available here). The proposed main modifications will clarify what the Inspector considers to be the necessary modifications to make the policy sound. These modifications are relevant to this policy as there are similarities Ref. Section/Policy Comment/Recommendation between the wording of the Neighbourhood Plan and Local Plan policy. Page 97 – Policy TC1: The Plan and this policy should have regard to Primary Shopping Area recent changes to the Use Class Order announced by the Government. During the course of the South Oxfordshire Local Plan examination, the Council produced a note on this for the Inspector (available here). In response the Inspector responded with some additional requirements (available here). For Policy TC5 in the emerging Local Plan, which relates to Primary Shopping Areas, the Inspector has said:

‘Whilst acknowledging that Part 2 starts with “Where planning permission is required”, the policy clearly only addresses the loss of retail uses when it should relate to all Class E uses, since there will be no purpose in distinguishing between them. This needs to be re-worded in a main modification to make it apply to the loss of E Class uses.’

We therefore recommend that TC1 is amended in this regard, replacing ‘retail’ with ‘Class E uses’.

TC1.2(c) In line with our Regulation 14 comments, the NPPG sets out that policies in neighbourhood plans should be concise and precise. This point could be re-worded to make it more concise, whilst achieving the same outcome. We recommend the following wording:

‘it is evidenced that there is no market interest in the site following one year of active and effective marketing’. Page 97 – Policy TC2: For clarity, the title of the policy should reflect the New Uses for Buildings content of the policy. We suggest the policy title within the Primary is replaced with ‘New Uses for Buildings within Shopping Area the Town Centre’. Page 97 – Footnote 37 We note the recent changes to the Use Class Order announced by the Government. During the course of the South Oxfordshire Local Plan examination, the Council produced a note on this for the Inspector (available here). In response the Inspector responded with some additional requirements (available here). Ref. Section/Policy Comment/Recommendation Page 98 – Policy TC3: TC3.2 Regal Site In line with our Regulation 14 comments, this policy should encourage the inclusion of the mentioned proposals, however it is unclear if there is any evidence to support if these proposals are viable or compliant with other development plan polices. We recommend you replace ‘should’ with ‘’will be encouraged that’. Page 98 – Policy TC4: TC4.1 Improve the Visitor In line with our Regulation 14 comments, the Economy emerging Local Plan 2034 contains Policy EMP12: Tourism, which looks at tourism development in different areas. Within the built- up areas of towns it supports larger scale developments including conference facilities, museums, heritage centres, hotels, guest houses and associated facilities for visitors. Outside of the built up areas, small scale development to support the visitor economy, including farm diversification and equine development, will be supported provided that the proposals are in keeping with the scale and character of the locality and would not adversely affect heritage assets or their setting.

We suggest some wording associated with the scale of appropriate development is added, such as:

‘which are of an appropriate scale and’ 103 – Policy TC5: Public In line with our Regulation 14 comments, this and Private Car Parks policy is overly restrictive and appropriate parking provisions should be guided by parking standards and evidence. It is not clear if this policy is based on parking standards or evidence. Page 100 – Policy TC7: TC7.1(b) Preservation of Visitor In line with our Regulation 14 comments, the Accommodation NPPG sets out that policies in neighbourhood plans should be concise and precise. This point could be re-worded to make it more concise, whilst achieving the same outcome. We recommend the following wording:

‘it is evidenced that there is no market interest in the site following one year of active and effective marketing’.

Ref. Section/Policy Comment/Recommendation During the course of the emerging South Oxfordshire Local Plan examination, main modifications have been proposed to EMP14: Retention of Visitor Accommodation. These proposed modifications can be currently viewed under reference 46 of document CSD13 dated 6 July 2020 (available here).The proposed main modifications will clarify what the Inspector considers to be the necessary modifications to make the policy sound. Page 105 – Objective This objective is not in line with the Oxfordshire MC06 County Council parking standards. We suggest the second sentence is amended as follows:

‘All new and extended homes should have adequate on-site parking and conform to the Oxfordshire County Councils parking standards.’ Page 106 – Paragraph Our Air Quality Officer has suggested that the 8.2.3 Plan could make reference to the South Oxfordshire Air Quality Developers Guidance, available here. Page 108 – Policy MC2: MC2.4 Access to Public This point is overly restrictive and does not have Transport regard to paragraph 56 of the NPPF which sets out that planning obligations must only be sought where they meet all of the following tests: ‘a) necessary to make the development acceptable in planning terms; b) directly related to the development; and c) fairly and reasonably related in scale and kind to the development.’

The scope of ‘development proposals’ is wide and therefore would capture some forms of development where it would be appropriate for them to contribute towards the provision and improvement of bus transport. Page 111 – Policy MC7: MC7.1 Provision of Electric We recommend ‘will’ with replaced with ‘should’, Vehicle Charging Points to give the policy some flexibility.

MC7.2 We recommend ‘will’ is deleted from this point.

It is not clear what evidence is supporting the requirements set out in this policy. The NPPG sets out that policies in neighbourhood plans need to be concise, precise and supported by appropriate evidence. Whilst it is acknowledged Ref. Section/Policy Comment/Recommendation that sustainable transport policies such as this have an important role to play in encouraging provision of electric vehicle charging points, the evidence supporting the requirement in this policy is lacking.

The previous Regulation 14 version of the plan included some text regarding the technical feasibility and we provided some suggested wording. This suggested wording gave some flexibility to the policy and we would suggest that similar wording is inserted into the policy:

‘The deliverability of this policy is subject to technical feasibility, the use of the most appropriate technology to reduce carbon emissions, and financial viability.’ Page 128 – Paragraph This paragraph sets out the community facilities 9.3.5 which will be safeguarded by Policy CF1. The list (i) to (xiv) includes a range of facilities including community buildings and sports grounds.

In a recent examination on the Wheatley Neighbourhood Plan, in a similar situation which identified community facilities, the examiner recommended that the recreation and sport field elements were deleted, as recreational and sporting fields are addressed in a specific fashion in national policy (NPPF paragraph 97) (examiner’s report available here, paragraphs 7.38 to 7.39).

On the basis that open space, sports and recreational buildings and land are considered differently through the NPPF, we recommend that these elements are deleted from the list in paragraph 9.3.6. Page 126 – Policy CF3: No evidence has been provided to show that the Local Green Space proposed Local Green Spaces meet the tests as defined in paragraphs 99-100 of the NPPF.

We recommend that the examiner seek clarification from the Town Council on this matter. Page 126 – Policy CF4: CF4.4 Wallingford’s Riverside Our comments from the Regulation 14 consultation still apply. The NPPG is clear that a neighbourhood plan should contain policies for the development and use of land. This point is Ref. Section/Policy Comment/Recommendation generally not concerned with development or land use, it is concerned with the capacity and users of the river which is outside the scope of what the neighbourhood plan should deal with. We recommend that this point is either deleted or reworded to address development and use of land. The focus could be shifted towards the facilities used by the river users.

We would also suggest that the focus is shifted away from separating ‘non-local’ and ‘local’ organisations. Wording such as:

‘Proposals for development of new or enhanced facilities for river-based organisations will be supported in line with other policies in the development plan.’ Page 128 – Policy CF6: We have concerns that this policy does not meet Health & Wellbeing the tests set out in paragraph 56 of the NPPF Service Provision which sets out that planning obligations must only be sought where they meet all of the following tests:

‘a) necessary to make the development acceptable in planning terms; b) directly related to the development; and c) fairly and reasonably related in scale and kind to the development.’

Point CF6.2 does not appear to meet these tests, as it implies proposals will be supported that exceed the contributions. Page 128 – 9.3.20 We have concerns with the second sentence in this paragraph which states:

‘This policy does not seek to influence the decisions of other statutory bodies in relation to CIL spending, but should be viewed as an opportunity for developers to make additional contributions to primary health care, over and above CIL, which may be viewed favourably during the decision-making process.’

We have concerns that what is being set out, would be unlawful. Page 129 – Policy CF7: As set out in our Regulation 14 comments, South Education Provision Oxfordshire have a CIL scheme, through which contributions are sought for educational provisions. How that money is spent, is a Ref. Section/Policy Comment/Recommendation budgetary decision, made by the appropriate council, which cannot be committed by a neighbourhood plan policy. A neighbourhood plan document can highlight the infrastructure that it believes should be prioritised, but it cannot commit CIL receipts, from a particular development, to be spent on specific items in a particular area. It is open to the Parish Council to make whatever commitments in its neighbourhood plan, it sees fit, on how it proposes to spend its proportion of CIL receipts. The payment of CIL is not discretionary and is not produced by a neighbourhood plan policy.

We are not clear what value this policy adds in light of the above. Page 147/148 – Table These tables are identical. One table should be C2 and C3 removed as an error. Page 149 Table C5 is a duplicate of C1. One of these tables should be removed as an error Page 156 Formatting error – Pictures need swapping as Station Road image is next to St Johns paragraph and vice versa.

Title

Name Robyn Tobutt

Job title (if relevant) Planning Policy Officer

Organisation (if relevant) South Oxfordshire District Council

Organisation representing (if relevant)

Address line 1 135 Eastern Avenue

Address line 2

Address line 3

Postal town

Postcode 01235422600

Telephone number

Email address [email protected] Response 7

Respondent Details

Information

Respondent Number: 7 Respondent ID: 146350948 Date Started: 11/08/2020 09:12:42 Date Ended: 11/08/2020 12:39:08 Time Taken: 3 hours 26 minutes 26 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Policy CF1: Further to our comments at the previous stage we remain supportive of this policy as it provides strong protection for Wallingford’s valued facilities including the Corn Exchange.

Policy TC3: We would reiterate previous comments regarding this site, in that as future theatre use is considered we would encourage the plan to encourage consultation with Theatres Trust at an early stage to help ensure the facility is fitforpurpose and sustainable.

We otherwise consider the plan to accord with the basic conditions.

Within Policy TC3 we would encourage the addition of a direction to consult with Theatres Trust if theatre use is proposed.

Public examination

No, I do not request a public examination

Title Mr

Name Tom Clarke MRTPI

Job title (if relevant) National Planning Adviser

Organisation (if relevant)

Organisation representing (if relevant) Theatres Trust

Address line 1 Theatres Trust

Address line 2 22 Charing Cross Road

Address line 3

Postal town London

Postcode WC2H 0QL

Telephone number

Email address [email protected] Response 8

Respondent Details

Information

Respondent Number: 8 Respondent ID: 146410024 Date Started: 12/08/2020 10:25:47 Date Ended: 12/08/2020 10:46:42 Time Taken: 20 minutes 54 seconds Translation: English IP Address: 85.115.52.201 Country: United Kingdom

Q1. Are you completing this form as an:

Agent

Your comments

Response received below via email from Optimis Consulting on behalf of Croudace Homes.

Q3. You can upload supporting evidence here.

File: P775 WNP Consultation Response vF.pdf File: Appendix A Comprehensive Framework Plan.pdf File: Appendix A Illustrative Masterplan.pdf File: APPEND~3.PDF

Your details and future contact preferences

Wallingford Neighbourhood Plan – Representations on draft submission

1.0 Introduction

1.1. Optimis Consulting act on behalf of Croudace Homes to promote land off Wantage Road, Wallingford for an allocation in the Local Plan and/or Neighbourhood Plan to deliver up to 1,100 dwellings which can be delivered alongside land immediately west of the site to deliver a scheme of at least 1,700 dwellings.

1.2. The site is adjacent to Wallingford, a Market town, one of four at the top of the Council’s identified settlement hierarchy and immediately abuts the existing settlement to the south. The characteristics of the site are such that, through a detailed and comprehensive maspterplanning process, a sustainable framework for development can readily be achieved, delivering residential development within the heart of the district at appropriate densities, along with community and commercial facilities, green infrastructure and biodiversity net gain. Details of the proposed scheme is found at appendix A.

1.3. In delivering the scheme, Croudace Homes is committed to providing social and community infrastructure facilities to support both existing and future residents of Wallingford. In recognition of existing development in Wallingford, Croudace Homes is able to deliver a standalone scheme up to 1,000 dwellings, which could look to deliver educational and health care facilities should they be required.

1.4. This Statement is made in response to the draft Neighbourhood Plan submitted to South Oxfordshire District Council in March 2020.

1.5. This statement also makes reference to the Examination in Public (EiP) of the South Oxfordshire Local Plan, which took place between 14th July and 7th August 2020.

2.0 General Observations

2.1. Croudace Homes actively support the role Neighbourhood Plans play in guiding development at the local level, recognising the value local knowledge plays in delivering sustainable development.

2.2. To this end, the following representation has been prepared with the intent of building upon the foundations of the draft Neighbourhood Plan, to assist with the preparation of successful plan making and demonstrate the Plan is capable of meeting the stated aims and objectives set out.

2.3. The Draft Neighbourhood Plan is described in paragraph 1.1.2 as being a planning tool to guide development across the period 2019 – 2034. The timeframe set out should be updated with a start point of 2021, assuming the South Oxfordshire Local Plan is adopted in December of this year. We would also suggest the Neighbourhood Plan period is extended to 2035 to maintain conformity with the South Oxfordshire Local Plan.

2.4. We would not advocate the Neighbourhood Plan advancing prior to the adoption of the Local Plan, as draft policies within the Local Plan are subject to change throughout the examination process and the Neighbourhood Plan will need to be amended to reflect this. This is most apparent in the case of allocating residential development within South Oxfordshire’s Market Towns.

2.5. As part of the Local Plan EiP, the Council has prepared a series of Main Modifications, which will require further consultation before being incorporated within the Plan. The prematurity of the consultation on the draft Wallingford Neighbourhood Plan removes the ability for the thrust of the main modifications to be incorporated within the draft Neighbourhood Plan prior to this consultation on the draft submission.

2.6. The role of the Market Towns in South Oxfordshire is explicitly emphasised within the emerging Local Plan and has been a central topic of discussion during the Local Plan EiP. It is not considered the current draft Neighbourhood Plan fully recognises the role Wallingford plays as key service centre within the district.

2.7. A key thread throughout the hearing sessions focused on policies specifically dealing with the plans approach to Market Towns, the draft policy for 15% growth of housing above Core Strategy levels. A considerable number of participants of the EiP, in addition to the Inspector, highlighted concern with the approach adopted by South Oxfordshire for growth in Market Towns. The draft Local Plan, which is the basis for this draft Neighbourhood Plan, was considered to effectively apply a cap on development over and above 15% in the Market Towns.

2.8. During the final hearing session, the Inspector made specific reference to the 15% growth in Market Towns being a minimum figure, to enable the continued and sustainable growth of these settlements throughout the entirety of the Local Plan period.

2.9. This significant amendment to the stance of the policy is not currently replicated within the draft Neighbourhood Plan. It is recognised that existing completions and commitments exceed the 1,070 dwellings identified in table 5d of the Local Plan, however in light of the Inspector’s comments it is appropriate to investigate Wallingford’s ability to accommodate further growth over and above this figure.

2.10. As currently drafted, the Wallingford Neighbourhood Plan makes no allocations for residential development, instead relying on existing commitments approved by South Oxfordshire to deliver housing. Crucially, the current Neighbourhood Plan removes the ability for residential growth during the latter part of the plan period and therefore fails to deliver sustainable development throughout the entire duration of the Plan.

AECOM Environmental Report 2.11. We are not aware of any investigation into the environmental capacity of Wallingford to accommodate growth. Whilst the AECOM Environmental Report sets out the ‘growth scenarios’ considered for Wallingford, the methodology undertaken is particularly narrow and failed to involve appropriate engagement with site promotors.

2.12. This is most evident in respect of ‘Site A’ promoted by Croudace Homes, in which paragraphs 5.12 and 5.13 of the AECOM Report refer to a letter from Oxfordshire County Council, in which raised concerns around the site in respect of minerals safeguarding, access and air quality are expressed. This letter was prepared in response to a draft allocation of part of Site A as part of the Wallingford Neighbourhood Plan.

2.13. The attachment to the OCC letter provides a copy of the Neighbourhood Plans Exhibition Boards, and states in respect of site A2:

“Current Evaluation: The site assessment process currently indicates that this site is the most suitable location for new housing allocation.” “Providing housing on this site will allow a critical mass of infrastructure and a range of housing types…”

2.14. The AECOM Report then proceeds to discount Site A within ‘growth scenarios’ solely on the response from Oxfordshire County Council.

2.15. With regards to minerals safeguarding, the approach taken by Oxfordshire County Council is inconsistent as other sites within Minerals Safeguarding Areas have been allocated for strategic development as part of the emerging South Oxfordshire Local Plan. Both Berinsfield and Culham are located within safeguarding areas and it is understood that Oxfordshire County Council supported their allocation.

2.16. Detailed on-site investigation has taken place in respect of the presence of minerals on Site A which has confirmed that mineral extraction is neither a viable nor realistic prospect on the site. Further information in this regard can be found in our response to the Oxfordshire Minerals and Waste Local Plan Part 2, which is provided in Appendix B.

2.17. The remaining concerns raised by Oxfordshire County Council are predicated on the basis that the site would rely on access to Shillingford Road and the impact this would have on traffic volumes, as well as air quality within the town’s Air Quality Management Area. Oxfordshire County Council failed to understand the correct context of Site A, which has the benefit of access arrangements directly on to Wantage Road. This is identified in the site boundary plan below.

2.18. The site is capable of utilising a primary access point off the Wantage Road roundabout, thereby directing the vast majority of traffic to the east of Wallingford and away from the AQMA. Any development proposals for the site would seek to maximise the use of sustainable transport methods into Wallingford, through existing road networks on Wilding Road or Shillingford Road. The site also has the ability to provide much needed social infrastructure for the town, including education and healthcare facilities. This has not been considered within the AECOM Report, nor the letter from Oxfordshire County Council, as part of a planning balance exercise.

2.19. The approach taken during site selection is not considered to appropriately assess the towns environmental capacity and capacity to accommodate greater levels of housing growth. This is particularly relevant for Wallingford given its role as a Market Town, in which surrounding settlements rely on for access to facilities and services.

3.0 Focused commentary

Paragraph 1.3.3 3.1. A justification for Wallingford engaging with the Neighbourhood Plan process is to benefit from developer contributions and funds obtained via the Community Infrastructure Levy, as explained in paragraph 1.3.3. However, in order for these funds to be provided, development of a suitable scale is required. As currently drafted, the Neighbourhood plan is overly restrictive and inflexible, such that major development over and above the existing commitments are unlikely to demonstrate compliance with policies set out in the Neighbourhood Plan. Existing commitments will have previously agreed s106 agreements and cannot be relied upon to secure additional funding.

3.2. There is a clearly defined need for additional/improved community services and facilities and this has been confirmed by both the Mayor of Wallingford, as well as a member of the Neighbourhood Plan Steering Group during the South Oxfordshire EiP. Failure to provide sufficient flexibility in the draft Neighbourhood Plan for additional development of a strategic nature, removes the potential for the required facilities and services to be provided.

Paragraph 1.5.4 3.3. The Basic conditions required for Neighbourhood Plans include a general conformity with strategic policies within the development plan, as well as the plan promoting sustainable development.

3.4. Due to the timing of this Neighbourhood Plan consultation, it cannot be confirmed that the plan demonstrates a general conformity with the emerging Local Plan as the hierarchical superior policy document. As has become evident throughout the Local Plan EiP, a number of changes to the Local Plan are required, and these will need to be factored into a revised Neighbourhood Plan submission.

3.5. Promotion of sustainable development is a further basic condition not met by the current draft Neighbourhood Plan. Given the Neighbourhood Plan fails to allocate any development throughout the entire Plan period, (solely relying on existing commitments and completions) the plan fails to promote sustainable development. This will be most evident during the latter parts of the plan period where existing commitments have been fully developed and no additional housing will be provided within one of the key service centres within the district.

Section 2.1 3.6. The vision for Wallingford is set out in Section 2.1 of the Plan. Of particular concern in the second bullet point of the overall vision, which states:

“Ensure that growth in Wallingford to 2034 will be managed carefully, resulting in sustainable and well-designed development that maintains the town’s special character”

3.7. As set out above, the Plan’s failure to allocate development fails to ensure effective management of appropriate growth within the Plan period. Instead, development will be disproportionately focused during the early years of the plan. In addition, the provision of much needed services and facilities for the local community (e.g. education and health care) will not be delivered unless significant public funding can be secured. Even then, it is unlikely that sufficient land can be identified where the landowner is willing and able to exclusively deliver community and social infrastructure.

Paragraph 2.3.7 3.8. Paragraph 2.3.7 indicates that sustainable development is at the heart of the proposals within the Neighbourhood Plan. This is simply not the case as the plan places too much emphasis on the 15% growth rate being a ceiling for development and makes no additional housing allocations for Wallingford, solely relying on existing consents. By failing to adequately assess the capacity of Wallingford to accommodate further growth, the plan does not recognise the importance of planning objectives, in particular the economic and social objectives of planning which relate to significantly boosting housing supply and ensuring adequate provision of services and facilities for all. The policy should be reworded as follows:

The WNP sets out a positive vision for the future of Wallingford within the context of its historical character and constraints. It seeks to balance the economic, social, and environmental objectives of planning whilst recognising the aspirations of the local community.

Paragraph 2.3.8 3.9. The wording of Paragraph 2.3.8 sets out that development which fails to accord with the defined areas in the proposals map, “…will be resisted.” Firstly, it is not appropriate for the Neighbourhood Plan to oppose all development other than that which is identified on Map 2. This is at odds with the stated vision for Wallingford which seeks to ensure the sustainable development of the Market Town.

3.10. Moreover, the Neighbourhood Plan is likely to be a relevant planning consideration for planning applications for a number of years post adoption. It is a realistic proposition that during the lifetime of the Neighbourhood Plan, circumstances both locally and nationally, will change and development not considered appropriate at the time of drafting the Plan may be required and supported by residents of Wallingford. The wording of paragraph 2.3.8 as suggested:

Inappropriate development, which is not consistent with these policies, or which lies outside of these defined areas, will not be supported, unless it can be demonstrated that there is a local need or local support from existing residents.

3.11. In amending this paragraph, the Neighbourhood Plan will have greater flexibility to adapt to future changes and can continue to be a relevant and helpful planning consideration in the context of determining future applications. 3.12. Furthermore, it is presumed the specific proposals and policies are TC3, EE1, EE2, MC6 and WS2 as defined in the proposals map below. On this basis, no development outside of the policy areas will be supported by the Neighbourhood Plan. This approach is at odds with the thrust of the whole Neighbourhood Plan and in particular Policy WS1 which encourages focus development within the built-up area of Wallingford.

3.13. Additional areas must be incorporated into the Proposals Map, including a clearly defined area to represent the built-up area of the town.

Policy WS1.1. 3.14. We do not support the provisions of subsections (a) and (b) of Policy WS1.1 which seek to control the extent and location of development within Wallingford.

3.15. Subsection (a) of Policy WS1 restricts development in the “…countryside areas outside of the town”. However, no distinction of what is considered as the town and countryside area is provided within the Neighbourhood Plan.

3.16. This is particularly relevant in the context of subsection (b), which refers to development being located within the “built-up area of Wallingford”. It is unclear as to what the built-up area consists of, and how this differs to the town itself as set out in subsection (a). Further clarity is required for Policy WS1 to be effective.

3.17. We also recommend land to the north of Wallingford is identified as a potential area for development, in accordance with the stated aim of delivering sustainable development throughout the entire plan period. Earmarking additional land to the north of Wallingford allows the Neighbourhood Plan to meets the aim of achieving sustainable development, whilst also reflecting the change required to the application of growth in the Market Towns, as required by the Inspector during South Oxfordshire’s Local Plan examination. The site could be safeguarded for future development at a time when local need can be demonstrated or as part of any Local Plan or Neighbourhood Plan review.

3.18. As identified above, this site is capable of providing additional community assets such as educational and healthcare facilities in a highly sustainable location within the lifetime of the current Neighbourhood Plan.

3.19. In the absence of this potential allocation and as a result of the overly restrictive stance of the Neighbourhood Plan, the additional community assets required in Wallingford are highly unlikely to be delivered, particularly in an equally sustainable location such as at land to the north of Wallingford.

Paragraph 2.4.4 3.20. The wording of paragraph 2.4.4 indicates that existing allocations “…are more than sufficient to meet the requirements for the WNP.” Given the outcome of the Local Plan EiP, this paragraph needs to be revisited. The growth level for Market Towns is to be described as a minimum figure, with no upper limit. Therefore, the wording should be amended to at the very least, state “minimum”.

Paragraph 2.4.20 3.21. The paragraph as drafted is incorrect. Policy WS2 does not allocate Site E, as the site benefits from an existing planning permission granted by South Oxfordshire District Council. The site will be developed (subject to granting of Reserved Matters approval) irrespective of whether the Neighbourhood Plan supported the principle of development at this location.

3.22. It is therefore irrelevant for the Neighbourhood Plan to ‘allocate’ any development. Policy WS2 should be solely focused on the way the Neighbourhood Plan can influence future applications for the site,

Paragraph 2.4.26 3.23. We do not agree with Paragraph 2.4.26 which states that Wallingford is well screened and unobtrusive in the wider landscape. This is particularly relevant for land to the north of Wallingford, where the existing properties on Wilding Road are clearly visible from the undeveloped land immediately north and from within the AONB to the north of the settlement.

3.24. The lack of screening is set out in the images below with the built from of Wallingford easily seen when viewed from Shillingford Road.

3.25. In this context, development of land to the north of Wallingford, in accordance with the Concept Plan (Appendix A) is capable of providing clearly defined, defendable and effective visual buffer of the settlement when viewed from the countryside and AoNB to the north of the site.

Policy WS4 3.26. As drafted, WS4 is ineffective. As set out above in respect of Policy WS2, clarity is required on the distinction between the built up area, the town, and the countryside for this policy to be effective.

Paragraph 9.1 3.27. Paragraph 9.1 sets out the vision and objectives for Community Facilities and Infrastructure. Of particular relevance are HO1 and EO1 which relate to health & social care and education, respectively. Both objectives state a requirement for housing developers to provide s106 and CIL funds to support this objective. We support this approach as the primary mechanism to deliver social and community infrastructure.

3.28. However, as previously highlighted, the current format of the draft Wallingford Neighbourhood Plan is such that development of a scale sufficient to deliver this infrastructure would be in direct conflict with the Plan, which seeks to restrict development other than that which benefits from existing consent.

3.29. For objectives HO1 and EO1 to be delivered, additional major developments within Wallingford are required so that the requisite financial contributions can be provided, along with sufficient land in the appropriate location(s).

Paragraph 9.2.29 3.30. Paragraph 9.2.29 confirms that Wallingford School is already operating at capacity and has a significant waiting list. This is particularly relevant in respect of the existing commitments, given none are providing secondary education facilities as part of the development. Once fully built out, existing allocations will place further stress on school places and will increase the number of private car generated trips within the district.

3.31. There is therefore, a clearly defined need for increased secondary school provision within Wallingford. This is expanded on in paragraph 9.2.29 which identifies the role Wallingford plays as a provider of education services to residents in both the town and surrounding villages.

3.32. As set out above, there is a requirement to promote additional housing stock to deliver further educational facilities, meeting both current and future demand. The current draft Wallingford Neighbourhood Plan fails to deliver this and as a result, fails to provide the sustainable development required in the town.

LEGEND

SITE BOUNDARY

SITE OWNERSHIP BOUNDARY (CROUDACE EAST SIDE / L&Q WEST SIDE) PRIMARY ACCESS

SPINE STREET

SECONDARY/EMERGENCY ACCESS

SECONDARY STREET

PEDESTRIAN DESIRE LINE TO LOCAL CENTRE

EXISTING TREE BLOCK

SOTWELL LANDSCAPE BUFFER HILL SHILLINGFRD ROAD HOUSE GREEN SPACE

RESIDENTIAL SUPERBLOCK

LOCAL CENTRE

SCHOOL

GREEN LINKS J:\JOB FILES\D2516 LAND AT WANTAGE ROAD, WALLINGFORD\DRAWINGS\07 FABRIK\04 ILLUSTRATOR FABRIK\04 WALLINGFORD\DRAWINGS\07 ROAD, WANTAGE LAND AT FILES\D2516 J:\JOB

PROJECT TITLE

WANTAGE ROAD LAND AT WANTAGE ROAD, WALLINGFORD

DRAWING TITLE

COMPHREHENSIVE FRAMEWORK PLAN

ISSUED BY London T: 020 7620 1453 DATE MAY 2020 DRAWN IK SCALE@A3 1:5000 CHECKED BS WILDING ROAD STATUS DRAFT APPROVED BS

DWG. NO. D2516_ 417

Notes: 1. This drawing is the property of fabrik ltd. It must not be copied or reproduced without written consent. 2. Only figured dimensions are to be taken from this drawing. All contractors must visit site and be responsible for taking and checking all dimensions 0 200m WALLINGFORD related to the works shown on this drawing. SCHOOL

THIS DRAWING MAY CONTAIN: ORDNANCE SURVEY MATERIAL BY PERMISSION OF ORDNANCE SURVEY ON BEHALF OF THE CONTROLLER OF HER MAJESTY’S STATIONERY OFFICE © CROWN COPYRIGHT 2017. ALL RIGHTS RESERVED. REFERENCE NUMBER 100022432. OS OPEN DATA © CROWN COPYRIGHT AND DATABASE RIGHT 2017 | AERIAL PHOTOGRAPHY © GET MAPPING LEGEND

SITE BOUNDARY

PRIMARY ACCESS

EMERGENCY ACCESS

SPINE STREET

WOODLAND BUFFER SECONDARY/TERTIARY STREET

SHARED STREET/PRIVATE DRIVE

RE-ALIGNED PAVEMENT/FOOTPATH PROW COUNTRY PARK RESIDENTIAL BLOCK

SOTWELL AONB SCHOOL HILL ALLOTMENTS SHILLINGFRD ROAD HOUSE LOCAL CENTRE

GREEN SPACE

EXISTING PLAY EQUIPMENT WOODLAND POCKET BLOCK AONB BOUNDARY PARK

ADJACENT L&Q DEVELOPMENT SITE POTENTIAL FUTURE LINK POTENTIAL FUTURE LINK TO L&Q SITE J:\JOB FILES\D2516 LAND AT WANTAGE ROAD, WALLINGFORD\DRAWINGS\07 FABRIK\02 PHOTOSHOP FABRIK\02 WALLINGFORD\DRAWINGS\07 ROAD, WANTAGE LAND AT FILES\D2516 J:\JOB

SCHOOL

VILLAGE GREEN L&Q DEVELOPMENT SITE

POTENTIAL POCKET PROJECT TITLE FUTURE LINK PARK LAND AT WANTAGE ROAD, WALLINGFORD WANTAGE ROAD POTENTIAL FUTURE LINK DRAWING TITLE

ILLUSTRATIVE MASTERPLAN

ISSUED BY London T: 020 7620 1453 DATE MAY 2020 DRAWN IK SCALE@A3 1:5000 CHECKED BS WILDING ROAD STATUS DRAFT APPROVED BS

DWG. NO. D2516_203

OXFORDSHIRE MINERALS AND WASTE LOCAL PLAN

PART 2 – SITE ALLOCATIONS

CONSULTATION

January 2020

RESPONSE FORM

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Oxfordshire County Council is preparing the Oxfordshire Minerals and Waste Local Plan, comprising two parts: Part 1 – Core Strategy; and Part 2 – Site Allocations (Sites Plan). Together these will guide all future Minerals and Waste Development within Oxfordshire.

The preparation of the Draft Sites Plan follows on from the adoption of the Minerals and Waste Core Strategy in 2017. The Core Strategy set out the vision, objectives, spatial planning strategy and policies for meeting development requirements for the supply of minerals and the management of waste in Oxfordshire over the period to 2031, and the Sites Plan sets out those mineral and waste sites needed to deliver the Core Strategy.

Oxfordshire County Council have published a Draft Minerals and Waste Local Plan: Part 2 Site Allocations Plan (the Sites Plan) for consultation.

The consultation is from

Wednesday 22nd January to Wednesday 4th March 2020

This Response Form contains all the questions in the Minerals and Waste Local Plan: Part 2 - Site Allocations (Draft Sites Plan), which should be read alongside it.

The Draft Sites Plan, and all supporting documents are available to view and download at:

https://www.oxfordshire.gov.uk/cms/content/new-minerals-and-waste-local-plan

If you would like to make comments, please complete a Response Form and send it to us by: • E-mail to: [email protected]

• Paper copy to: FREEPOST OXFORDSHIRE COUNTY COUNCIL

• Online at: https://consultations.oxfordshire.gov.uk/consult.ti/system/register? If you are sending a response to the FREEPOST address, please make sure you write “MWPlans” in the top left hand corner of the envelope to make sure it reaches us.

Please send your response to reach us by 4pm on Wednesday 4th March 2020

Paper copies of this form, if required, are available from the Minerals and Waste Policy Team (contact details below). If you are unable to use this form, we will accept comments by email or post.

Comments must be received by 4.00pm on Wednesday 4th March 2020.

Alternative formats of this publication can be made available on request. These include other languages, large print, Braille, audio cassette, compute disk or e-mail. Please contact the Minerals and Waste Policy Team:

Direct Line: 07979704458 or 07741607726 Email: [email protected]

Please return completed forms to 2 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Part 1 – Respondent Details

1(a) Personal details

Title Mr First Name Michael Last Name Jenner Job Title (where relevant) Organisation (where Croudace Strategic relevant) 1(b) Agent details Only complete if an agent has been appointed Title Mr First Name Robbie Last Name Locke

Job Title Senior Planner (where relevant) Organisation (where Optimis Consulting relevant) 1(c) Contact address details If an agent has been appointed, please give their contact details Address Line 1 Optimis Consulting

Line 2 16 St Cuthbert’s Street

Line 3 Bedford

Line 4

Postcode MK40 3JG Telephone No. 01234 330624 Email address [email protected] Are you writing as A resident A parish council

A local business A district council

Minerals industry A county council

Waste industry ✓ Other (Developer with interest in land in South Oxfordshire)

Please return completed forms to 3 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Where did you hear about the consultation? Please tick the appropriate boxes if you wish to be notified of any of the following and to show how you wish to be contacted: (If you do not tick any of the boxes below, you will not be contacted again with regard to the preparation of the Minerals and Waste Local Plan) Contact Contact by Email by Post Publication of future consultations on the Minerals and Waste ✓ Local Plan – Part 2 Site Allocations Plan. Submission of the Minerals and Waste Local Plan – Part 2 - ✓ Site Allocations Plan. Examination of the Minerals and Waste Local Plan – Part 2 - ✓ Site Allocations Plan. Adoption of the Minerals and Waste Local Plan – Part 2 - Site ✓ Allocations Plan. Any other consultations on publications produced by ✓ Oxfordshire County Council Minerals and Waste Team

Data Protection and Freedom of Information Oxfordshire County Council is a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27th April 2016). For more details on how the Council will handle your personal information, please use the link below to access our Privacy Notice. Hard copies of this can also be provided on request:

https://www.oxfordshire.gov.uk/sites/default/files/file/corporate-governance/GenericPrivacyNotice.pdf The information on this form is collected by Oxfordshire County Council as a data controller. The purposes for collecting this data are: 1. To assist in preparing the Oxfordshire Minerals and Waste Local Plan: Part 2 – Site Allocations. The preparation of this plan is required by the Planning and Compulsory Purchase Act 2004. 2. To contact you, if necessary, regarding the responses given in relation to this consultation.

The above purposes may require public disclosure of any data received by Oxfordshire County Council, in accordance with the Freedom of Information Act 2000 (as amended).

By responding to this consultation, you agree that Oxfordshire County Council can hold contact details and related responses. These details will only be used in relation to preparation of the Oxfordshire Minerals and Waste Local Plan: Part 2 – Site Allocations. You also accept that responses cannot be treated as confidential and that any comments made, including information provided in support of a site nomination, will be made publicly available for viewing in paper form and/or on the Council website in due course. Relevant information may be passed to external parties where required for the purposes of preparation of this plan only.

By responding to the invitation to nominate a site for possible inclusion in the Oxfordshire Minerals and Waste Local Plan: Part 2 – Site Allocations you understand and accept that this is without prejudice to the decisions that will be taken by the County Council on the site allocations and related policies to be included in the Plan.

The information collected will be held and retained by Oxfordshire County Council in paper and/or electronic form for the duration of the preparation of the Oxfordshire Minerals and Waste Local Plan: Part 2 – Site Allocations and for a period following adoption of the Plan in accordance with the Council’s retention schedule. Consultation responses will be removed from the Council website when the Plan has been adopted.

You have the right to contact the Information Commissioners Office if you are unhappy with anything to do with our use of your personal information. If you have any concerns regarding the processing of your data, please contact [email protected]

Please sign and date the form: Please note that response forms that are not signed and dated will not be accepted (this can be typed in for electronic forms).

Please return completed forms to 4 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Signature Optimis Consulting Date: 26/02/2020 (on behalf of Croudace Strategic) Section 2: Mineral Context

Questions on Mineral Requirements

Q1 Mineral Requirements Do you agree with the mineral requirements identified? Please tick Yes No Don’t know

Please give reasoning for your answer

Q2 Sharp Sand and Gravel 5% contingency Do you agree with the addition of 5% contingency for sharp sand and gravel? Please tick Yes No Don’t know

Please give reasoning for your answer

Q3 Soft Sand and Crushed Rock 10% contingency Do you agree with the addition of a 10% contingency for soft sand and crushed rock? Please tick Yes No Don’t know

Please give reasoning for your answer

Please return completed forms to 5 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Question on Sharp Sand and Gravel – North and South allocations

Q4 Do you agree with the identified split for Sharp Sand and Gravel between the north and south of the County? Please tick Yes No Don’t know

Please give reasoning for your answer

Question on Mineral Safeguarding Areas

Q5 Do you consider a revision of the Minerals Safeguarding Areas (as shown on the Policies map adopted with the Core Strategy) is required? Please tick Yes ✓ No Don’t know

The Minerals Safeguarding Areas, as designated in Policy M8 of the Minerals and Wate Local Plan Part 1 includes land to the north of Wallingford, part of which is currently being promoted for residential development by Croudace Strategic. Immediately adjoining land owned by Croudace Strategic is land being promoted by L&Q Estates.

For the purposes of this Site Representation, the site; “land to the north of Wallingford” consists of land promoted by both Croudace Strategic and L&Q Estates.

A number of previous Representations have been made for the site in respect of the site’s designation as a Mineral Safeguarding Area. These Representations have been made for the Oxfordshire Minerals and Waste Local Plan Core Strategy and the emerging South Oxfordshire Local Plan.

The previous Representations for the site confirmed that the site was not to be made available for a strategic location for future mineral working. This position has not changed, and the landowner maintains that the land is not to be used for mineral extraction, both now and in the future. It is therefore questioned as to whether this site should remain designated both within Mineral Strategic Resource Area 5 (Thames & Lower Thames Valleys – Standlake to Yarnton (Sharp Sand and Gravel), or in the

Please return completed forms to 6 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Mineral Safeguarding Area (Policy M8) for Sharp Sand and Gravel, as this is not a deliverable policy position. It is instead requested that this parcel of Area 5 is entirely removed from the Oxfordshire Minerals and Waste Local Plan Core Strategy Policy Map.

Paragraph 4.63 of the Oxfordshire Minerals and Waste Local Plan Core Strategy highlights that mineral deposits are to be safeguarded where they are considered to be located in ‘economically viable’ areas. In respect of land to the north of Wallingford, we would raise concerns over the economic viability of the site for mineral extraction.

Due to the proximity of the site to both the existing settlement of Wallingford (south and west) and the AONB (north and east), the scope for mineral extraction on the site is dramatically reduced. Appropriate stand-offs will be required on all sides of the site to protect the amenity of neighbouring uses. In addition, it would be anticipated that there would be a significant amount of local opposition to any future application proposing a mineral extraction facility (and associated activities) at land to the north of Wallingford.

Policy M8 of the Minerals and Waste Local Plan Part 1 states that non- mineral related development within Mineral Safeguarding Areas will not be permitted unless;

• The site is allocated for development in an adopted Local Plan or neighbourhood plan; or • The need for the development outweighs the economic and sustainability considerations relating to the mineral resource; or • The mineral will be extracted prior to the development taking place.

The site is not allocated within either the emerging South Oxfordshire Local Plan or Wallingford Neighbourhood Plan, however, the site is being actively promoted for residential development. Given the recent strategic expansion of Wallingford, the proposed site represents the most logical location for future expansion and unnecessary constraints Policies should be avoided as they may constrain the logical expansion of one of the key towns within South Oxfordshire.

With respect to the sustainability considerations for the site, as highlighted above, the existing limitations of the site in terms of its proximity to existing residential dwellings, road networks and the AONB markedly reduce the area available for mineral extraction, thus reducing the economic value of mining the site. Moreover, Policy C5 of the Minerals and Waste Local Plan Part 1 restricts proposals for mineral extraction where these will have unacceptable adverse impact on residential amenity. It is recognised that any mineral extraction for the site will negatively impact the residential amenity of existing properties to the south and west of the site.

Please return completed forms to 7 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Finally, whilst it is recognised that minerals could technically be extracted from the site prior to development, the lack of economic value of the site, combined with the potential conflict with Policy C5 suggests this would not be an appropriate course of action. The timeframe for extraction would inhibit the immediate need for logical housing sites such as this.

There are other sites within the Mineral Strategic Resource Area 5 which are considerably more suited to future mineral extraction. For example, land to the west of Wallingford occupies an area of approximately 900 hectares and has fewer constraints in terms of proximity to existing settlements, the AONB and existing road networks. Further afield, particularly to the west of Oxford there are large swathes of land with significant mineral deposits in rural and unconstrained locations.

The emerging Minerals and Waste Local Plan Part 2 allocates two sites for mineral extraction, to deal with the overall mineral requirements throughout the Local Plan Period. The estimated reserves for each allocation exceed the Local Plan requirements and will therefore go some way towards contributing to mineral requirements for future Local Plans. Given the availability of additional mineral reserves of significant capacity, located in more appropriate and less constrained sites within Oxfordshire, it is recognised that the future need for mineral extraction can be accommodated without the use of land to the north of Wallingford.

Conversely, the need for housing (both at a local and national scale) is well documented and the site is readily available to contribute to meeting such need. In light of the recent changes in governance within South Oxfordshire, we would highlight that residential development on a site outside the Green Belt, such as land to the north of Wallingford should be designated for future residential development as part of the Local Plan. Such an allocation would go some way to alleviate concerns currently being expressed by Councillor’s in South Oxfordshire in respect of the draft allocation of sites within the Green Belt for residential development, whilst also ensuring the draft Local Plan can progress to examination and adoption without jeopardising funding secured as part of the Oxfordshire Growth Deal.

For the reasons stated above, it is requested that the Minerals Safeguarding Areas are reviewed and land to the north of Wallingford is removed as a policy designation in Minerals and Waste Local Plan Core Strategy.

Please return completed forms to 8 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Question on Mineral Consultation Areas

Q6 Do you consider a revision of the Mineral Consultation Areas (as shown on the Policies map adopted with the Core Strategy) is required? Please tick Yes ✓ No Don’t know

Based on our response to the previous question, it is considered that a review to the Mineral Consultation Areas is undertaken as part of the emerging Minerals and Waste Local Plan Part 2.

The Minerals Consultation Area is based upon the Minerals Safeguarding Area plus a 250m buffer. Relevant applications for land within a Conservation Area will be required to include consultation with the County Council.

In respect of our Representation on Question 5 and the request to remove the site from the Minerals Safeguarding Area, it is also recommended that the Minerals Consultation Area is reviewed to exclude the site from this policy designation.

Question on Mineral Infrastructure

Q7 Are there any further mineral infrastructure facilities that should be safeguarded? Please tick Yes No Don’t know

Please give reasoning for your answer

Overall Mineral Context

Please return completed forms to 9 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Q8 Do you have any other comments on the Minerals Context Section of the Draft Site Allocations Plan? Please tick Yes No Don’t know

Please give reasoning for your answer

Section 3: Waste Context

Question on allocation of landfill sites

Q9 Do you agree that the Sites Plan should not contain any landfill sites for the Plan period? Please tick Yes No Don’t know Please give reasoning for your answer

Q10 Overall Waste Context

Please return completed forms to 10 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Do you have any other comments on the Waste Context Section of the Draft Site Allocations Plan? Please tick Yes No Don’t know

Please give reasoning for your answer

Please return completed forms to 11 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Section 5: How we chose our Preferred Options

Question on Site Assessment Process

Q11 Do you support the Site Assessment process used to identify the Minerals and Waste Sites for inclusion within the Plan? Please tick Yes No Don’t know

Please give reasoning for your answer

Question on the Site Assessment Findings

Q12 Do you support the findings of the Minerals and Waste Site Assessments? Please tick Yes No Don’t know

Please be specific and provide Site No and Name if referring to the findings of a particular site/s and give reasoning for your answer. Use extra sheets if required.

Please return completed forms to 12 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Section 6: Minerals Site Assessment

Question on Preferred Option 1 SG20b – Land between Eynsham and Cassington

Q13 Do you agree with the identification of Preferred Option 1 – SG20b – Land between Eynsham and Cassington to meet the identified need within northern Oxfordshire? Please tick Yes No Don’t know

Please give reasoning for your answer

Question on Preferred Option 2 SG42 – Land at Nuneham Courtenay Q14 Do you agree with the identification of Preferred Option 2 – SG42 – Land at Nuneham Courtenay to meet the identified need for Sharp Sand and Gravel within southern Oxfordshire? Please tick Yes No Don’t know Please give reasoning for your answer:

Please return completed forms to 13 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Question on Preferred Option 3 SS12& CR12 – Land at Chinham Farm

Q15 Do you agree with the allocation of Preferred Option 3 – SS12& CR12 – Land at Chinham Farm to meet the identified Soft Sand and Crushed Rock need within the Plan Period? Please tick Yes No Don’t know

Please give reasoning for your answer:

Question on Preferred Option 4 SS18 & CR22 – Hatford Quarry West Extension Q16 Do you agree with the allocation of Preferred Option 4 – SS18 & CR22 – Hatford Quarry West Extension to meet the identified Soft Sand and Crushed Rock need within the Plan Period? Please tick Yes No Don’t know

Please give reasoning for your answer

Please return completed forms to 14 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Overall Minerals Preferred Options

Q17 Do you have any other comments on the Preferred Options for Minerals? Please tick Yes No Don’t know

Please provide your comments:

Please return completed forms to 15 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Section 7: Waste Site Assessment

Preferred Options Waste Sites

Q18 Do you agree with the allocation of these sites as Preferred Options for Waste Sites? Please tick as applicable Site Site Yes No Don’t No. know

011 011 Finmere Quarry Finmere

026 026 Whitehill Quarry, Burford

103 103 Lakeside Industrial Estate, Standlake

229 229 Shellingford Quarry, Shellingford

249B 249B High Cogges Farm, Witney

274 274 Moorend Land Farm, Thame

279 279 Rear of Ford Dealership, Ryecote Lane 287 287 Ardley Fields, Ardley

289 289 Overthorpe Industrial Estate, Banbury

Please refer to the Site No in your response Please give reasoning for your answer

Please return completed forms to 16 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Strategic Waste Sites

Q19 Do you agree with the allocation of the sites below as Strategic Waste Facilities for the Plan Period? Please tick Site Site Name Yes No Don’t know No 287 Ardley Fields 289 Overthorpe Industrial Estate, Banbury Please state to which site you are referring to in your answer and please give reasoning

Additional Strategic Waste Sites

Q20 Are there any other sites that should be included as Strategic Waste Sites? Please tick Yes No Don’t know

Please give reasoning for your answer:

Please return completed forms to 17 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Section 8: Preferred Mineral Sites for Allocation Policies

Policy SP1 Land between Eynsham and Cassington (SG20b)

Q21a Do you support Policy SP1 Land between Eynsham and Cassington (SG20b)? Please tick

Yes No Don’t know Q21b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers.

Policy SP2 Land at Nuneham Courtney (SG42)

Q22a Do you support Policy SP2 Land at Nuneham Courtney (SG42)? Please tick

Yes No Don’t know Q22b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Please return completed forms to 18 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Policy SP3 Land at Chinham Farm (SS12 & CR12)

Q23a Do you support Policy SP3 Land at Chinham Farm (SS12 & CR12)? Please tick

Yes No Don’t know Q23b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Policy SP4 Hatford Quarry West Extension (SS18 & CR22)

Q24a Do you support Policy SP4 Hatford Quarry West Extension (SS18 & CR22)? Please tick

Yes No Don’t know Q24b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Please return completed forms to 19 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Section 9: Preferred Waste Sites for Allocation Policies

Policy SP5 Finmere Quarry, Finmere (011)

Q25a Do you support Policy SP5 Finmere Quarry, Finmere (011)? Please tick

Yes No Don’t know Q25b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Policy SP6 Whitehill Quarry, Burford (026)

Q26a Do you support Policy SP6 Whitehill Quarry, Burford (026)? Please tick

Yes No Don’t know Q26b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Please return completed forms to 20 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Policy SP7 Lakeside Industrial Estate, Standlake (103)

Q27a Do you support Policy SP7 Lakeside Industrial Estate, Standlake (103)? Please tick

Yes No Don’t know Q27b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Policy SP8 Shellingford Quarry, Shellingford(229)

Q28a Do you support Policy SP8 Shellingford Quarry, Shellingford (229)? Please tick

Yes No Don’t know Q28b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Please return completed forms to 21 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Policy SP9 High Cogges Farm, Witney (249B)

Q29a Do you support Policy SP9 High Cogges Farm, Witney (249B)? Please tick

Yes No Don’t know Q29b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Policy SP10 Moorend Lane Farm, Thame (274)

Q30a Do you support Policy SP10 Moorend Lane Farm, Thame (274)? Please tick Yes No Don’t know Q30b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Please return completed forms to 22 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Policy SP11 Rear of Ford Dealership, Ryecote Lane (279)

Q31a Do you support Policy SP11 Rear of Ford Dealership, Ryecote Lane (279)? Please tick Yes No Don’t know Q31b Should we include any further information within the Policy? Please tick

Yes No Don’t know Please give reasoning for your answers

Policy SP12 Ardley Fields, Ardley (287)

Q32a Do you support Policy SP12 Ardley Fields, Ardley (287)? Please tick

Yes No Don’t know

Q32b Should we include any further information within the Policy? Please tick

Yes No Don’t know

Please give reasoning for your answers

Please return completed forms to 23 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Policy SP13 Overthorpe Industrial Estate, Banbury (289)

Q33a Do you support Policy SP13 Overthorpe Industrial Estate, Banbury (289)? Please tick

Yes No Don’t know

Q33b Should we include any further information within the Policy? Please tick

Yes No Don’t know

Please give reasoning for your answers

Any other information to be considered within the Site policies

Q34 Is there anything else that should be considered in both the Minerals and Waste Site Allocations Policies? Please tick

Yes No Don’t know

Please give reasoning for your answers

Please return completed forms to 24 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Oxfordshire Minerals & Waste Local Plan – Part 2 Site Allocations Consultation January 2020 – Response Form

Annex 2 Supporting Documents

Supporting Documents

Q35 Do you have any comments on the findings of the supporting documents including the Sustainability Appraisal and Habitats Regulations Assessments? Please tick Yes No Don’t know

Please reference which supporting document you are referring to in your answer and please give reasoning for your answers

Please return completed forms to 25 [email protected] Closing Date 4.00pm Wednesday 4th March 2020

Title

Name Robbie Locke

Job title (if relevant) Principal Planner

Organisation (if relevant) Optimis Consulting

Organisation representing (if relevant) Croudace Homes

Address line 1 16 St

Address line 2 Cuthberts Street

Address line 3

Postal town Bedford

Postcode MK40 3JG

Telephone number 01234 330624

Email address robbie@optimisconsulting.co.uk Response 9

Respondent Details

Information

Respondent Number: 9 Respondent ID: 146411432 Date Started: 12/08/2020 10:47:11 Date Ended: 12/08/2020 11:19:25 Time Taken: 32 minutes 13 seconds Translation: English IP Address: 85.115.52.201 Country: United Kingdom

Q1. Are you completing this form as an:

Agent

Your comments

Response received below via email from Barton Willmore on behalf of L&Q Estates.

Q3. You can upload supporting evidence here.

File: 24709 A3 GW MK 20 08 11WNP Reps SODCFINAL.pdf File: Appendix 1 Site Location Plan.pdf File: APPEND~2.PDF File: APPEND~3.PDF File: APPEND~4.PDF File: APC9A4~1.PDF

Your details and future contact preferences

Planning Policy Team, South Oxfordshire District Council, 135 Eastern Avenue, Milton Park, Abingdon. OX14 4SB 24709/A3/GW/MK/dw

BY EMAIL: [email protected] 11th August, 2020

Dear Sir/Madam,

REGULATION 15 DRAFT WALLINGFORD NEIGHBOURHOOD PLAN (FEBRUARY 2020): REPRESENTATIONS SUBMITTED ON BEHALF OF L&Q ESTATES LAND NORTH OF WILDING ROAD, WALLINGFORD

Barton Willmore LLP is instructed by L&Q Estates (previously known as Gallagher Estates) to submit representations to the draft Wallingford Neighbourhood Plan Regulation 15 Consultation Version (February 2020), hereafter referred to as the ‘WNP’ which is currently subject to public consultation. The representations consider the evidence base to the WNP which includes the Strategic Environmental Assessment, Housing Needs Assessment and the Sites Assessment Document.

L&Q Estates control Land to the north of Wilding Road, Wallingford (identified in the WNP as Site A1), hereafter referred to as ‘the Site’; the Site is currently being promoted alongside Site A2 which is controlled by Croudace Strategic. The Site extends to approximately 21.5ha as shown on the Location Plan at Appendix 1.

Representations have been submitted on behalf of L&Q Estates (under their previous name, Gallagher Estates) to promote the Site through previous consultations (October 2019 and November 2018) on the WNP Draft Policies and to the Site Assessments consultation in August 2017. We are also continuing to promote the Site through the emerging South Oxfordshire Local Plan 2034 (ELP) and the emerging Oxfordshire Plan 2050.

Background

For context, Wallingford is categorised as one of three ‘market towns’ alongside Henley -on-Thames and Thame within the South Oxfordshire Local Plan 2034 Publication Version, which was submitted for Examination in March 2019. The Local Plan seeks to deliver an overall housing requirement of 3,873 homes for the Market towns, which includes 1,070 new homes in Wallingford. The Local Plan does not require the WNP to allocate any sites for growth in Wallingford over and above existing commitments and completions.

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South Oxfordshire District Council’s (SODC) Emerging Local Plan (ELP) was assessed through the examination hearings which were held in July and August 2020. Barton Willmore, acting on behalf of L&Q Estates, participated in the Matter 19 Wallingford hearing. The Inspector’s closing statement was issued on 7th August and, in this, the Inspector advised that modifications to ELP Policy H3 are required for soundness. These include:

i) Amending the housing figures so that there are ‘at least’ i.e. minimums. ii) That neighbourhood plans could exceed the housing figures set out in Policy H3. iii) Policy H3 in conjunction with Policy WAL1 should support proposals which would deliver community facilities where there is an identified need.

The ELP Proposed Modifications are due to be subject to public consultation in Autumn 2020 and adoption is anticipated by the end of 2020/early 2021.

Against this background, it is incumbent for the WNP to have adequately assessed the potential for a higher quantum of residential development to be allocated in a sustainable manner . Furthermore, it is also necessary for the WNP to have adequately assessed the need for new or improved community facilities/infrastructure – not just as a potential constraint to accommodating growth – and for positive consideration of development opportunities which can deliver these facilities.

Wallingford is a highly sustainable settlement and a key location within the district to focus growth. On this basis, the WNP should not be unduly restrictive in, particularly given that the only mechanism in the ELP to allocate housing in the market towns is through NDPs.

The Site was identified as one of three possible strategic allocations for residential development in the WNP Sites Assessment consultation document in 2017 (site reference as ‘Site A1’) with the two additional sites being Land North of Wallingford (East) (reference Site A2) immediately adjacent to the Site, and Land North and South of Winterbrook (reference Site E). At the time of the WNP Sites Assessment consultation, the emerging Local Plan for South Oxfordshire determined that there would be a minimum of 226 new dwellings over the Neighbourhood Plan period which were to b e delivered through allocated sites in Wallingford.

The Site was also previously considered as part of a larger site allocation option for Wallingford known as ‘Site A’ during the preparation of the South Oxfordshire Core Strategy. Site A comprised the western portion controlled by L&Q Estates and the eastern portion controlled by Croudace (also known as Land North of Wallingford (East) or Site A2 through the WNP).

L&Q Estates has continued to promote the site for residential-led development through SODC’s ELP process and previously through engagement with Wallingford Town Council (WTC) in the preparation of the WNP.

The Site has the potential to accommodate up to 400 new homes, a new primary school, community uses and public open space (as set out within the Vision Document - September 2016 at Appendix 2).

The Draft WNP is premature in setting the strategy for housing delivery in Wallingford based on draft housing policies in the emerging ELP submitted for Examination in March 2019. The ELP was tested at examination in July and August 2020 and where Proposed Modifications to the relevant strategic policies are expected to be made (as summarised above). Against this background, the WNP is expected to be inconsistent with the requirements of ELP Policies H3 and WAL1 including a proper assessment of additional housing growth and/or opportunities for resolving infra structure deficits. As set out below, we have serious concerns that the WNP fails to meet the basic conditions.

L&Q Estates’ representation to the Regulation 15 Draft WNP Consultation is set out below. Barton Willmore’s Environmental Planning Team produced a supporting technical review of the Strategic Environmental Assessment (SEA) which was submitted in response to the consultation draft WNP

24709/A3/GW/MK/dw - 3 - 11th August, 2020

(Regulation 14) in October 2019. The SEA Review scores the WNP SEA against the legal requirements and the rationale behind exclusion of Site A1 from the consideration of it being a site allocation. The SEA Review also addresses the growth scenarios which have been assessed in Chapter 5 of the WNP SEA Report produced by AECOM. In summary, the SEA Review concludes that the reasons for Site A1 being rejected as a ‘reasonable alternative’ were on the basis of being located within a Strategic Resource Area and Mineral Safeguarding Area (MSA) and concerns relating to access and the potential impact on the Air Quality Management Area (AQMA).

The SEA Review has been included at Appendix 3 for your references.

Chapter 1 - Wallingford

Chapter 1 of the WNP includes a ‘glossary’ of various plans which are referenced within the document (see page 11). In our view, it would be beneficial for the WNP to include reference to the Oxfordshire Housing and Growth Deal (HGD) which is an important document in the context of the ELP and this WNP. In particular, the HGD’s commitment to delivering 100,000 homes in Oxfordshire by 2031. This includes the allocation of some 5,600 homes (approx.) which are not currently planned for through adopted or emerging Local Plans.We discuss the implications of the HGD and the housing need which is to be accommodated within South Oxfordshire in more detail in our response to Chapter 2 of the WNP, below.

We recommend that, for consistency with the ELP, paragraph 1.1.2 of the WNP be amended to refer to a plan period of 2019-2035.

Chapter 2 - Strategy for Wallingford

The Vision and Objectives set out in section 2.1 of the WNP are broadly supported. However, in respect of housing provision, we consider the vision and objectives to be both vague and unduly negative, and therefore fails to contribute towards the achievement of sustainable development and are not consistent with national policy.

Specifically, we note that the vision refers to ‘housing for an increasing local population’ and that WNP 02 states that ‘new homes will be located on allocated sites set out in this Plan to meet local housing needs in terms of affordability and social housing, family and retirement homes’. As we address in more detail below in response to Policy WAL 2, the proposed allocation of housing is considered premature in advance of the ELP and is not founded upon an adequate evidence base.

In order to satisfy the basic conditions set out at paragraph 1.5. 4 of the WNP, we recommend the following modifications to the vision and objectives:

Replace the first and second bullets under Vision, as follows:

“Growth in Wallingford up to 2035 will contribute towards the achievement of sustainable development, meeting the need for growth including infrastructure whilst protecting and enhancing the established character of the town.”

Replace the fifth bullet under Vision, as follows:

“New housing to meet the needs of a growing population will consist of a mix of types, tenures and size, including starter homes, family-sized and retirement accommodation. It will be located to promote walking, cycling and sustainable modes of transport.”

Amend the wording of WNP 01 as follows:

“The growth of Wallingford to 2035 will be managed in order to respect the town’s unique heritage, historic and landscape setting, and the natural environment.”

24709/A3/GW/MK/dw - 4 - 11th August, 2020

Amend the wording of WNP 02 as follows:

“New homes will be delivered primarily on allocated sites identified in this Plan to help meet local housing needs, seeking to improve affordability, and providing a mix of housing including market and affordable housing, with starter, family and retirement homes.”

Amend the wording of WNP 04 as follows:

“New development will be provided to secure necessary infrastructure to provide for the well-being and needs of residents and those who depend on the facilities and services in the town.”

Section 2.3 Overall Strategy

Section 2.3 of the WNP focuses upon the natural and historic environment including assets which are to be protected. Paragraph 2.3.5 identifies that ‘appropriate housing growth in line with local need will be accommodated’. As we comment in more detail below, consideration of housing need at this stage is considered premature in advance of the ELP’s adoption. Furthermore, the Housing Needs Assessment (HNA) does not provide an appropriate evidence base to support the low level of housing provision which is proposed through the WNP.

In the absence of reserve sites and/or additional allocations to provide flexibility, the WNP does not in our view satisfy the basic conditions.

Against this background, and taking account of the positive approach to planning in the NPPF (specifically Paragraphs 11 and 170 (b) of the NPPF (2019)), which requires recognition of the intrinsic character and beauty of the countryside as opposed to its protection for its own sake (as contained in previous national policy guidance), we strongly object to paragraph 2.3.7 of the WNP.

Policy WS1: The Strategy for Wallingford

Criterion WS1.1(a) in Policy WS1 states that the strategy is to support a locally appropriate level of housing growth in the town whilst also restricting inappropriate development in the countryside are as outside the town.

As we explain elsewhere in these representations (specifically under subsection ‘Housing’ within Section 2.4 Planning Policy Framework for Wallingford and in response to Policy WS2 below), it is premature at this stage to establish what is a locally appropriate level of housing growth in the town. We are also concerned that the HNA is flawed and does not provide an appropriate evidence base.

Furthermore, as set out above it is inconsistent with national policy (specifically Paragraph 170 (b) of the NPPF (2019)), imposing a severe restriction on ‘inappropriate development’ in the countryside, particularly in the absence of any flexibility or criteria-based policies which could allow for the consideration of proposals on unallocated sites. The consequence is that unallocated sites in potentially less sustainable locations within the District being brought forward in the event of the most relevant policies becoming out of date.

We note many of the other criteria contained within Policy WS1 provide for the protection and enhancement of the environment. In our view, this reflects the unduly negative and restrictive approach to the delivery of housing which does not satisfy the basic conditions. We therefore seek the deletion of the second part of WS1.11(a) in Policy WS1.

Section 2.4 Planning Policy Framework for Wallingford (Subsection Housing)

It appears that the HNA has failed to consider the additional housing need arising from Oxford City which should be accommodated within South Oxfordshire District. Whilst it considers affordable

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housing need, it has failed to consider the extent to which affordability will be improved, as required by national policy.

The HNA is also silent on uplifts which should be applied for economic growth, consistent with the 2014 Oxfordshire SHMA and the aspirations contained within the Oxfordshire Local Industrial Strategy.

Paragraph 2.4.11 advises that the figure of 1,070 homes up to 2034 set out in the ELP is ‘an appropriate level of new housing growth for the town and will provide the needed affordable housing’. However, it was made clear by the ELP Inspector that this is a minimum and, furthermore, that neighbourhood plans for the Market Towns (including Wallingford), as part of their preparation, should assess the potential to accommodate a higher level of growth. As we have set out in these representations, this has not adequately formed part of the WNP’s preparation.

For these reasons, we object to paragraph 2.4.19 of the WNP which states that the housing requirement for Wallingford in the ELP has been revised to zero as existing comments satisfy the housing need in the town. Notwithstanding the findings of the HNA, which we do not consider to be robust - this statement is plainly false. The proposed housing number for Wallingford contained in the ELP does not positively respond to the identified housing needs of the area which are to be delivered through the ELP, nor does it respond to the capacity to accommodate sustainable development through further strategic housing sites.

In conclusion, in order to properly address the housing needs of the area including providing for flexibility, the WNP should include an additional allocation of site A1 controlled and promoted by L&Q Estates (potentially as part of a strategic allocation including Site A2).

Policy WS2: The Land Allocation for Housing in Wallingford

In response to the modifications which are anticipated to Policy H3 of the ELP (as summarised above), the housing requirements contained within Policy WS2 and the supporting text should make clear that it is the minimum level of housing growth to be delivered at Wallingford.

For the reasons set out above, we recommend that Policy WS2 is revised to include an additional allocation of Site A1 (potentially as part of a strategic allocation of Site A including A2) including appropriate policy criteria relating to its development. This should include th e anticipated capacity of the allocation, the proposed access strategy, design requirements, infrastructure requirements and any mitigation to be provided as part of the development. On behalf of L&Q Estates, we have previously submitted a Vision Document with a proposed masterplan for the development of the site.

We note that paragraph 2.4.9 lists ‘identified issues’. Criterion (ii) identifies that schools, sports facilities and the medical centre are all at capacity. However, the WNP does not appear to propose any solutions for how new infrastructure and facilities could be delivered to address these issues. In our view, this fails to meet the basic conditions and is inconsistent with the requirements of Policies H3 and WAL1 of the ELP which seek to secure identified infrastructure needs through new development. In this respect, our client’s land at North Wallingford provides opportunities for delivering new education, health and sports infrastructure. These potential benefits have failed to be taken into account as part of the WNP’s preparation.

Having regard to the similar status of site B and site E, both of which have planning permission but have yet to be developed, it is unclear why Policy WS2 only deals with site E. Furt hermore, the WNP does not include any consideration of the likely trajectory for the delivery of homes from these sites and elsewhere within the town in order to meet the proposed housing requirement. In the absence of any reserve allocation, we are concerned that the WNP will fail to meet the proposed requirement up to 2035. We are concerned that the lack of any flexibility – indeed, the severe restriction which is proposed through the WNP – could prevent the development and infrastructure needs of Wallingford from being met.

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We would welcome an opportunity for further dialogue with WTC regarding the potential of the site to contribute towards the sustainable growth of Wallingford.

Policy WS3: Housing Density

We agree with Paragraph 2.4.27 that a minimum density of 50 dwellings (as set out in Policy START5) would likely be inappropriate for new development at Wallingford. Previously, we have commented on Policy STRAT5 in response to the February 2019 consultation on the ELP (Publication Version), that the minimum requirement of 50 dwellings per hectare is inconsistent with paragraph 127 of the NPPF (2019) and, in addition to this, the supporting SODC Housing T opic Paper (January 2019) does not provide justification for this requirement.

We are concerned that Paragraph 2.4.27 considers the approach set out in Policy DES8 of the ELP to be inappropriate notwithstanding the proposed minimum of 25 dwellings per hectare set out in Policy WS3 of the WNP. We support the approach to densities as set out in Policy DES8 of the ELP which seeks a minimum density of between 30 and 50 dwellings per hectare. This approach is considered broadly consistent with the proposed requirement set out in Policy WS3 and expressed as a range may provide greater clarity for decision-making.

Policy WS4: Development Within the Built-up Area

Further to our previous representations, which previously requested further clarity and a map to illustrate the extent of the built-up area, we welcome the addition of the sites assessed in addition to the further clarification on the constitution of ‘infill development’.

Site A1 adjoins the existing residential settlement of Wallingford and is well-connected with the existing settlement.

Chapter 3 - Design and Character Assessment

It is understood that the supporting Housing Needs Assessment (HNA) has been used to inform this section of the WNP (Section 3.3) and its supporting housing policies. In addition to the WNP, we have also reviewed the supporting HNA and would raise that whilst this report identifies a housing need, this cannot be justified as it has been based on surveys which have been provided to local residents of which not all of the residents have responded.

Considering that the primary data is derived from surveys to residents and provides a perception of housing need rather than definitive data, we do not consider that this would form a robust basis for determining the Housing Need for Wallingford. The HNA also does not consider provision to be made for housing up to 2034. The HNA is also supported by existing secondary data which has been derived from the 2011 Census data, national and local authority data, household and population projections.

We are also concerned with Paragraph 3.3.8 which again, sets out that “the HNA supports the view that no more than the 1,070 housing figure set by SODC is required to meet local needs”. As above, the ELP is to be modified so that the housing figures presented in Policy H3 are minimums and this should be reflected in the WNP (principally Policy WS2

The supporting South Oxfordshire Housing and Economic Land Availability Assessment (SHELAA) (January 2019) will be used to identify suitable, available and achievable sites and within the SHELAA (2019), Site A (SHELAA Ref. 928) has been identified as being suitable, available and achievable for development and could support 2336 homes.

In terms of directing growth towards Wallingford, as it is one of three Market Towns identified in the ELP, it is considered that Wallingford would present a greater potent ial location for further strategic growth. The Site would present an additional opportunity for residential development and would enable Wallingford to develop sustainably.

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As the Town Council will be aware, Oxford City has an unmet need in which the oth er districts in Oxfordshire have been required to consider as part of their housing requirements in their emerging and recently adopted Local Plans. Given the sustainability of Wallingford, it is considered that this location would be able to accommodate additional sites for development. On the basis of the above, we consider that the level of housing which has been proposed for Wallingford is insufficient. Wallingford is capable of accommodating further growth and, in comparison to the other market towns (Henley-on-Thames and Thame), is less constrained in terms of the North Wessex Downs and Chilterns AONB and Air Quality Management Area (AQMA). This evidence has been identified in the Sustainability Appraisal (SA) which supports the SODC ELP.

Additionally, the Air Quality Annual Status Report (June 2019) (prepared by SODC) includes a recent amendment during this year, which confirms that an error in NO 2 levels was recorded during March and April 2017. The report confirms that there have been reductions in pollution levels in Wallingford, Henley and Watlington which has meant that there is the potential to revoke the AQMA status for Wallingford all together. As such, subject to continued improvements in the air quality and appropriate monitoring, air quality would cease to be a constraint for future development in Wallingford. An additional technical note prepared by Wardell Armstrong supports this and has been provided at Appendix 5.

Policy HD1: Design

L&Q Estates would ensure that the design of the scheme would be subject to detailed masterplanning to ensure the proposals would be in accordance with the Emerging Plan (and supporting design guides) and with the WNP once ‘made’.

Policy HD3: Affordable Housing and Housing Mix

Given the strategic scale of Site A1 and the proposals for approximately 400 dwellings, there would be the provision of 40% affordable housing and the development proposals would provide a mix of housing types. The scheme would also provide new Public Open Space and woul d protect the existing green space which has been identified in Policies ENV1 and ENV2.

Chapter 4 - Historic Environment and Archaeology

Policy HA3: Views and Vistas

The proposals seek to create a memorial park on-site and would provide buffers which would protect the key views into and from the North Wessex Downs and Chilterns AONB which is located to the north of Site A1.

Chapter 5 - Natural Environment

Policy EV1: New Green Spaces and Green Corridor

There is an existing Local Green Space (LGS) located on Wilding Road and south of the Site. The development proposals would seek to maintain, enhance and protect this area of green space. The development proposals which are contained at Appendix 2 propose a green corridor which would run through the centre of the scheme containing the neighbourhood play space and would contain the proposed memorial park.

Policy EV2: Protect Existing Amenity Spaces and Wallingford Green Network

We consider that the proposals for the scheme are in accordance with this policy as they propose to connect the scheme with the existing and designated LGS which is situated on Wilding Road. The

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Green Corridor proposed as part of the Development Framework would ensure that the designated LGS is maintained, enhanced and protected for community use.

In terms of connecting Site A1 with the existing Public Rights of Way (PRoW) network , there is an existing footpath which is located along the northern edge of Site A which con nects Site A1 to Wantage Road and Shillingford Road.

Chapter 6 - Employment and Economy

We have no comments to make with regards to policies relating to employment.

Chapter 7 - Town Centre, Retail and Tourism

We have no comments to make with regards to policies relating to the town centre, retail and tourism.

Chapter 8 - Movement and Connectivity

Policy MC2: Access to Public Transport

We support Policy MC2 in that it favours proposals for development where there is good access to public transport. Site A1 benefits from being situated in close proximity to bus stop which is connected with the X2 service and provides frequent services to Didcot and Oxford and provides connections to Milton Park and Abingdon. Both Didcot and Oxford offer direct rail connections to Reading and London Paddington. The closest bus stop to Site A1 is situated on Wantage Road and is within the 400m requirement set out in the Policy.

Site A1 is also in close proximity to facilities and services in Wallingford town centre meaning that non-car modes of transport (i.e. walking and cycling) offer viable alternatives to the private car for local trips.

Chapter 9 - Community Facilities and Infrastructure

Policy CF3: Local Green Space

The implications for future development on Local Green Spaces have now been included within the revised policy and confirms that development will not be permitted on the designated areas. The scheme proposals to connect with the existing local green space on Wilding Road and provide a green corridor which will enhance biodiversity and create public open space to be used by the community.

Policy CF5: Local Amenity Provision

Policy CF5 states that:

“The developers of new housing developments in excess of 50 houses will be encouraged to provide local business premises to serve the needs of the residents of the development (such as convenience shops and pubs).”

Whilst we understand and support this Policy in principle, in order to ensure flexibility, we remain of the view that ‘convenience shops and pubs’ is amended to ‘community facilities’.

Policy CF7: Education Provision

L&Q Estates supports Policy CF7 which requires proposed residential developments to mitigate the impacts on educational provision in Wallingford. As proposed in the Vision Document (Appendix 2), Site A1 has the potential to accommodate a 2 Form Entry Primary school on-site which would be in walking and cycling distance from new and existing homes within Wallingford. In addition to this, the

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school would also be within walking distance to the town centre which is approximately 1.4km away (17 minute walk or 6 minute cycle).

In addition to Site A1 coming forward for development, the eastern parcel of the Site is controlled by Croudance (Land North of Wallingford - East - Site A2) and come forward collaboratively to form a comprehensive scheme. This would have a greater capacity to accommodate education provision for Wallingford and surrounding areas including potential secondary school provision which the WNP identifies as being needed (para 9.2.29). However, the WNP fails to address this infrastructure deficit which we consider is unsustainable.

Chapter 10 - Community Aspirations

We have no comments to make on this section.

Chapter 11 - Monitoring Delivery of The Plan

We have no comments to make on this section.

SITE ASSESSMENT DOCUMENT (INCLUDING APPENDIX A - SITE ALLOCATIONS)

We have reviewed the Site Allocations Document, which has informed the WNP and the decision to allocate Site E for residential development. There were three sites which were considered further for residential development, these were Site A (Land North of Wallingford), Site D (South of Hithercroft Farm Industrial Estate) and Site E (Land North and South of Winterbrook Lane, Wallingford).

We wish to comment specifically on the justification for discounting Site A from further consideration. Appendix A identifies the following constraints for Site A (A1 and A2) as being located within the Strategic Resource Area and Mineral Safeguarding Area (MSA), traffic from the eastern parcel onto Shillingford Road and Castle Street, the negative impacts on the Air Qualit y Management Area (AQMA) and Site A1 not being located in close proximity to public transport.

We wish to rebut the claims regarding Site A1 being located within the MSA and the implications that development would have on Site A1. The Oxfordshire Minerals and Waste Local Plan identified Site A1 as being within a Minerals and Safeguarding Area (MSA) and that the safeguarded resource are river terrace deposits which comprise of sand and gravel.

The ELP includes two strategic site allocations which are both located within the MSA, Berinsfield and Culham (totalling up to 5,200 dwellings). The inclusion of these two allocations demonstrates that being located within a designated MSA is not an absolute constraint to development . Development plan policy allows for sites in MSAs to be allocated for residential development.

Additionally, Wardell Armstrong have prepared a Geological Report and an intrusive investigation of Site A1 in order to support representations which Barton Willmore LLP submitted in September 2018 to the Minerals and Waste Local Plan. The Geological Report evidences that the minerals which have been identified on Site A1 are not commercially viable and would therefore have no economic value. We have included a copy of the Geological Report at Appendix 4. Given Site A1’s close proximity to residential development (i.e. adjoining the settlement boundary of Wallingford), it is considered that mineral extraction in this area would have a negative impact on residential amenity and would therefore, not be realistically feasible. The report evidences that the minerals which would be extracted, are not of commercial interest and that the imposition of the MSA designation at this Site cannot be justified.

Overall, the Site’s location within the MSA is not an ‘in principle’ constraint. Furthermore, site -specific assessment demonstrates that the Site can be developed for housing without the loss of a commercially viable mineral resource.

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The other reason given for the Site being rejected from further consideration was due to the proposed implications on the Air Quality Management Area (AQMA). An assessment undertaken by Wardell Armstrong for L&Q Estates concluded that the development of the Site would have a ‘negligible’ impact on the AQMA. Our supporting SEA Review (Appendix 3) also reinforces that the impact would be ‘neutral’ when the SEA was scored against the SEA Objectives.

As set out in our response to Chapter 3 of the WNP above, the Air Quality Annual Status Report (June 2019) includes the recent amendment confirms that an error in NO 2 levels was recorded during March and April 2017 and that pollution levels in Wallingford, Henley and Watlington have reduced. If the pollution levels continue to fall in these areas, it is indicated that the AQMA designation may be removed. Therefore, this would not be a constraint to future development at Site A1. Please also see the supporting technical note prepared by Wardell Armstrong at Appendix 5.

In order to address the claims regarding Site A1 being unsustainable in terms of public transport, the site is located in close proximity to a bus stop located on Wantage Road. This is the X2 Bus Service which provides direct connections to Didcot, Oxford, Milton Park and Abingdon. The Site is also a 12 minute walk to Wallingford Town Centre and 10 minute s walk to the bus stop located on Wantage Road. Additionally, there is the potential for a bus service to be extended and incorporated within the Site to accommodate future residents of the development.

In addition to the above, the WNP and accompanying Sites Assessment Document considers that the development of Site A1 to be harmful to the North Wessex Downs and Chilterns AONB. We wish to rebut this claim and highlight that, on review of the SA, it is considered that other Market Towns (such as Henley-on-Thames), are more constrained by the AONB in comparison with Wallingford. The development of Site A1 would also require a robust landscaping scheme in order to ensure that development would not have a detrimental impact on the AONB and would conserv e the setting of the North Wessex Downs and Chilterns AONB. The Vision Document (Appendix 2) illustrates the development framework which shows how Site A1 can be designed in order to ensure that the north- eastern corner is sympathetic to views to and from the AONB. Additionally, Figure 6 of the Vision Document (Page 17) demonstrates that this corner of the Site will remain open and will comprise of the new Memorial Park and areas of Public Open Space which will retain this part of the site as being undeveloped. It is considered that Site A1 will have less of a detrimental impact on the AONB in comparison with the eastern parcel (Site A2) which immediately abuts the AONB (along the eastern edge of Site A2). Although, residential development on both sites would also benefit from the woodland buffer which is located between Site A2 and Shillingford Road.

On the basis of the above, we object to the ‘Assessment Conclusions’ which state that Site A is unsuitable, unavailable and unachievable and have rebutted the reasonings for discounting the Site for further consideration. This is also contrary to the SHELAA (January 2019) which confirms that Site A is suitable, available and achievable for residential development and that it could accommodate a greater number of homes (2336) in comparison with the existing commitments at Sites B and E.

APPENDIX B - SITE ASSESSMENT FOR SITE E (SODC WAL5; SHELAA 821)

We wish to comment again that this site has already received planning permission and therefore, we would suggest that an alternative site is considered for additional development. This site was granted outline planning permission in August 2019 for up to 502 units including an extra care facility and primary school (Application Reference: P16/S4275/O). Given that the application was granted on 9 th August 2019 and the draft WNP was published on 30 th August 2019 (with the updated version published in February 2020), we consider that it is unsustainable to allocate sites which have already been granted permission as this does not take into consideration the increased housing requirement for South Oxfordshire nor does it consider Oxford City’s unmet housing need. Again, we consider that additional sites should be allocated given the suitability of Wallingford as a sustainable location for strategic growth.

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APPENDIX C - BACKGROUND INFORMATION

We wish to comment on Section C.12 (Commentary on Housing Development for Wallingford), notably paragraph C.12 which states:

“The full integration of affordable and open market housing is a requirement of the SODC Core Strategy CSH3. The provision of Affordable Housing is integral to Wallingford Neighbourhood Plan. Proposals that meet the SODC target of 40% affordable housing will be supported.”

We would reiterate that the WNP should be aligned with the policies in the ELP rather than the Core Strategy (2012) which is out of date. Instead, this section should align with Policy H9 (Affordable Housing) which sets out a requirement of 40% affordable housing on sites with more than 10 dwellings.

APPENDIX D - NATURAL ENVIRONMENT

We have no comments to make on this supporting Appendix.

APPENDIX E - WALLINGFORD CHARACTER AREA ASSESSMENT OUTSIDE THE HISTORIC CORE

We have no comments to make on this supporting Appendix.

CONCLUSION

Overall, we have addressed the reasons which have been provided by Wallingford Town Council for rejecting Site A1 as a ‘reasonable alternative’ for helping to meeting the housing needs of Wallingford. We consider that rejecting the Site on the basis of being located within a MSA and for the potential impact on the AQMA to be unjustified and that the Site is suitable, achievable and available for development, as identified in SODC’s SHELAA (January 2019 Update). This has also been addressed through Barton Willmore’s review of the WNP SEA Report (Appendix 3).

Despite the housing requirement for Wallingford being proposed as 1,070 in the ELP, the allocation of Site E for development is already an existing permission, which was granted in August 2019, prior to the publication of the draft WNP. The SODC ELP was assessed through the examination hearings which were held in July and August 2020. Barton Willmore, acting on behalf of L&Q Estates, participated in the Matter 19 Wallingford hearing. As explained above, prior to the ELP having been tested through the Examination and an agreed housing figure for Wallingford having been established, we consider that the WNP to be premature.

Taking all of the above into account, following the examination of the ELP, the WNP should include the additional allocation of Site A1 at North Wallingford.

L&Q Estates wishes to continue ongoing correspondence with Wallingford Town Council in order to continue to promote the Site for potential strategic allocation within the WNP and would welcome further opportunities to discuss this with the Steering Group.

We trust that the above representations will be of assistance to Town Council and would be grateful if we could receive confirmation that these representations have been registered as being duly made.

Please could we request to be notified of the Council’s decision on whether to formally adopt the neighbourhood plan.

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Please do not hesitate to contact the writer should you have any queries or require further clarification on 0118 943 0000 or [email protected].

Yours faithfully,

MICHAEL KNOTT Director

Encs: Appendix 1 - Site Location Plan Appendix 2 - Vision Document, September 2016 Appendix 3 - Barton Willmore Review of the SEA Appendix 4 - Geological Report (Wardell Armstrong) Appendix 5 – Air Quality Qualitative Assessment Update – July 2020 (Wardell Armstrong)

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1. INTRODUCTION 3 FIGURE 1: SITE LOCATION 4 1.1 Background 4 1.2 Site Location & Description 4 FIGURE 2: DESIGNATIONS & ALLOCATIONS PLAN 7 1.3 Land Control 4 FIGURE 3: LOCAL FACILITIES 11 1.4 Planning Context 6 1.5 Landscape Character & Resource 8 FIGURE 4: SITE ANALYSIS 12 1.6 Visual Amenity 8 1.7 Mitigation 8 FIGURE 4: DESIGN CONCEPT 14-15

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3. VISION 13 3.1 Emerging Development Concept 14 3.2 Emerging Development Framework 16 3.3 Land Budget 16 3.4 Development Character 18

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Existing site Route of the Juvenile 1 access and 2 PRoW located 3 woodland PRoW off to north east of located within Wantage site. the western Road/A4130 extents of the roundabout. site.

Shillingford Access to View across the 4 Road west 5 adjoining land 6 centre of the of the site off Doyley Road. site towards the boundary. AONB beyond.

Existing area Bradburn Close Existing site 7 of public open 8 cul-de-sac 9 access off space adjacent leading to site Wantage Road. to the south boundary. boundary of the site.

5 Land North of Wallingford Vision Document

1.4 PLANNING CONTEXT

SOUTH OXFORDSHIRE CORE STRATEGY (DECEMBER 2012) SOUTH OXFORDSHIRE EMERGING LOCAL PLAN 2031 AND STRATEGY FOR WALLINGFORD 1.4.5 In response to the figures published within the 2014 SHMA 1.4.8 Page 24 of the document therefore considers the ‘Market 1.4.1 Policy CSWAL1 ‘The strategy for Wallingford’ outlines 10 (and ongoing cross boundary working being lead by the Towns and Larger Villages outside Science Vale’, which includes objectives to achieve the overall strategy for Wallingford; of Oxfordshire Growth Board) SODC published a Local Plan 2031 Wallingford. The document states that: which one is to ‘identify land for 555 new homes’. ‘Refined Options’ document for consultation in Spring 2015. The document suggested that SODC could need to plan for an ‘Our towns and larger villages are the most sustainable places 1.4.2 In accordance with the housing strategy objective outlined additional 5,100 homes when compared with the requirement in to live, they have the best access to jobs, shops, schools, within Policy CSWAL1, the Core Strategy allocates a ‘Greenfield the adopted Core Strategy. public transport connections and other services and facilities Neighbourhood’ to the west of Wallingford under Policy and have vibrant clubs and community organisations. Our CSWAL2. Paragraph 12.12 of the Core Strategy sets out that: 1.4.6 To achieve this the document sets out 8 potential options existing strategy in the Core Strategy seeks to enhance the in planning for housing growth, arranged in a colour coded vitality of towns and larger villages by allowing for a proportion “Locating strategic housing growth at Wallingford will add diagram. Options A and B are outlined as being the most of housing and employment growth. By maintaining the new households to the town and help support town centre favourable: network of larger service centres we can help ensure that businesses and services as well as the Science Vale economic everyone in the district has access to a basic range of services area. 555 homes are proposed to 2027”. ‘Option A: The Core Strategy approach. and facilities.’ There are elements of the Core Strategy distribution that we 1.4.3 Section 18 of the Core Strategy sets out how the strategy and 1.4.9 Question 6 of the Refined Options document asks whether there think are appropriate to retain, such as the identification of the its objectives will be implemented with reference to specific are any particular places within or around the market towns and roles and character of different places: Didcot growth point, policies. At page 122 policy CSWAL2 is discussed and the table larger villages where some of the additional growth could be the market towns, larger villages, smaller villages and other outlines that the ‘target’ is to have the development delivering located. villages.’ on site by 2014/15. In achieving this, the table outlines that the indicator for performance will be net dwelling completions by ‘Option B: Science Vale and ‘sustainable settlements.’ EMERGING WALLINGFORD NEIGHBOURHOOD PLAN year on the site. 1.4.12 The site lies within the Wallingford Neighbourhood Area and This option strongly supports the vision we have set out. It is will therefore be subject to Neighbourhood Plan policies 1.4.4 Should completions not be on target, the table advises of further an evolution of ‘Option A’ which extends the housing focus of and objectives. The Neighbourhood Area was designation actions: Science Vale beyond Didcot. It also makes clear that we are was approved on 1st May 2015 and the Baseline Report was committed to protecting the most important natural and historic subsequently published in February 2016. • Review issues and identify appropriate actions that can be taken environments in South Oxfordshire; for example in the AONBs, to bring development forward the Green Belt and conservation areas.’ 1.4.13 The Neighbourhood Plan is still currently being prepared and is expected to address the matters of site allocations at • Consider the need to bring forward other allocations 1.4.7 ‘Option C’ is the least favourable which considered the Wallingford and the overall level of new housing and other possibility of accommodating all of the additional housing within development which is to be planned for. • Consider the need to release alternative sites through a DPD the Science Vale. The document outlines that there is already a commitment to high levels of housing within this location. 1.4.14 Within the Baseline Report the site is identified as ‘Site A’ and Therefore options outside of the Science Vale should be identified as previously being submitted in conjunction with the pursued and indeed the document advocates this approach as SODC Core Strategy (2012). The Town Council describe the it considers that other areas within South Oxfordshire “…could Baseline Report as a ‘living document’. To date two versions benefit from taking some of the additional housing growth (for have been produced; version 1.0 in February 2016 and more example, in terms of viability of shops and services), so we recently version 2.0 in May 2016. No further details concerning would not wish to restrict it to one part of the district”. the progress of the Neighbourhood Plan are currently available.

6 Land North of Wallingford Vision Document

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7 Land North of Wallingford Vision Document

1.5 LANDSCAPE CHARACTER & RESOURCE

1.5.1 The North Wessex Downs Area of Outstanding Natural Beauty 1.6.3 The site is visible from locations immediately to the east and encircles the site to the north and east with its open, expansive from rising ground to the north. Vegetation coverage along the landscape and little vegetation cover. The sensitivity of the southern half of the site’s eastern boundary, to the western edge AONB ‘5D Downs and Scarp: Moreton Plain’ character area to of Shillingford Road, is notably patchy and allows clear open the changes proposed on the site is considered to be medium/ glimpse views into the site resulting in a medium sensitivity. low. 1.6.4 The public right of way which follows the northern boundary, 1.5.2 The local landscape character area ‘7. Wessex Downs and clearly offers open views over the site due to its proximity. The Western Vale Fringes’ follows a similar footprint and forms sensitivity of views here are considered to be medium and parallel conclusions with an anticipated low sensitivity to change. medium/high with the overall sensitivity reduced as a result the Whilst the site reflects the characteristics identified within the footpaths ‘urban fringe’ characteristics given the high visibility of studies undertaken by/on behalf of Natural England and South the properties which back onto the Site and the traffic noise from Oxfordshire District Council, the site forms a minor part of these Shillingford Road and Wantage Road. character areas and is only visible from a small area of its open farmland. From these locations the built up area of Wallingford is 1.6.5 Views from rural public rights of way to the north, within the visible and already forms an impression on the landscape. The AONB, offer elevated, open views towards the majority of the site has no physical or visual relationship with the vast majority site, with properties at Wallingford visible beyond. The sensitivity of its remaining character area to the north and west due to the of views from locations here are considered to be high. rising form of the Sinodun Hills and vegetation cover. 1.7 MITIGATION 1.5.3 The sensitivity of the landscape resource is considered to be medium given the conflicting low value of the site as an open 1.7.1 An extensive landscape strategy seeks to lessen the visual arable field with no defining or special landscape characteristics impact of any development of the site from more sensitive against the Agricultural Land Classification as Grade I excellent locations. These include: quality, as well as being within a Mineral Consultation Area for its potential for gravel and sand extraction. • introducing new beech tree planting along the southern half of the eastern boundary, with development set back from the 1.6 VISUAL AMENITY boundary by 10m;

1.6.1 Due to the flat nature of the site and its surrounding context, • introducing a no-development zone along the northern the site is visually contained from locations to the east, south boundary where land will be retained for agricultural and the and west. To the west, the physical form of the properties along creation of a new public park; and Wantage Road and vegetation to road margins and front/rear • extensive tree planting to streets, public spaces and new gardens restricts the visibility of the site. Similarly, to the south woodland blocks along the northern boundary. the residential properties which back onto the site restrict its visibility with occasional openings where there are breaks in the building line. 1.7.2 Other mitigation measures include restricting building heights to 2 storeys; and sensitive treatments to the exposed rear 1.6.2 To the east, a woodland block which lines the eastern side of gardens to the south and southwest. The landscape character Shillingford Road restricts the visibility of the site from locations will be preserved through the use of woodland blocks, specimen to the east and within the Thames Valley. From more distant parkland trees which will help to close off the visibility of the site elevated locations to the northwest, southeast and southwest and at the same time will be characteristic of the local parkland the site is not visible largely due to intervening vegetation as found within the ‘ Wessex Downs and Western Vale Fringes’; and landform, and viewed at a distance >2km would not be as well as creating new ‘open’ view corridors to the AONB from discernible within the larger built up area of Wallingford. The Shillingford Road to the east and Wilding Road to the south, sensitivity of views from these locations are on the whole thereby maintaining its sense of openness. considered to be negligible/low.

8 Land North of Wallingford Vision Document Site Context & Analysis

2. SITE ANALYSIS

The vision for Land at NorthWallingford can only be realised successfully through detailed knowledge of the site’s features, constraints and opportunities.

9 Land North of Wallingford Vision Document

2.1 CONTEXT LEGEND 2.1.1 Wallingford is a market town located on the west bank of the River Thames. The settlement boundaries of Wallingford are distinctly ite oun defined by the River Thames to the east, Bradford Brook (a stream that runs west-east into the Thames) to the south, the A4130 istoic oc cente strategic road to the west, and the Chilterns AONB and open im o eto countryside to the north. The close proximity of the rail links and the primary road network to the town and site provides excellent wider ies n oos connectivity. oo one n 2.1.2 Approximately 1km to the south east of the site is Wallingford m ontou ines town centre, which includes a series of notable distinctive historic buildings, many of which are set along the main high street and the uic its o s town's market square which is off St. Mary's Street. oott ecetion oute 2.1.3 As well as being the historic heart of the town, the town centre ie provides a wide range of typical facilities including retail, public te uic outes houses, churches and a library. Much of the remainder of the settlement area comprises medium-density housing, the majority of eite which has been constructed after 1950. Approximately 500m to the iste uiins e n south east of the site is Wallingford Secondary School. eeence oction n untit 2.1.4 There are a series of pedestrian and cycleway connections through ceue onuments nn Wallingford that include public footpaths and a recreational route that runs along the western side of the Thames. n se

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2.2 OPPORTUNITIES & CONSTRAINTS Track

60m 57m 2.2.1 The site itself is relatively free from constraints, however, any m D development of the site should have regard to the following: SHILLINGFORD

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• The North Wessex Downs AONB located to the north, east and Cottages north west of the site;

• The PRoW located along the north west site boundary; ROAD

Track Preston • Open views into and out of the site, towards and from higher Crowmarsh land to the north west; Sotwell Hill House m55m D Path • A general lack of vegetation and structure within the site, aside 58m from a woodland belt centrally located to the east; Track

• Exposed rear private gardens along the site boundary, currently Sand Elms creating an unattractive settlement edge; Track

• Existing tracks and access points providing opportunities for Drain Track future linkages; LEGEND Path Site • An area of open space to the south providing opportunities for Nursery

51m further community integration; ROAD Existing PRoW E G A T N A • An opportunity to provide a new primary school centrally- W Arable land

located within the site adjacent to new areas of open space and 57m Residential connected to new and existing walking and cycling routes; Pp LEGEND Ho Nursery/paddocks • A war memorial situated outside of the site to the south, Path Site commemorating F/O. J. A Wilding and SGT. J. F Andrew for WANTAGE Existing vegetation sacrificing their lives to save inhabitants of Wallingford during Existing PRoW

56m WW2; and 55m Arable land Existing open space 56m WAY

Path ROAD • Low voltage overhead powerlines to the east of the site to be DOYLEY SEVERALLS Residentialm D G War memorial IV E RD D R L Y diverted. N

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O ANDREW Fir Tree IN Sch ST War memorialS C L School Residential NICHOLAS O Cottage S E ST WANTAGE Rear gardens Path 5m Contours PW Nursery/paddocks Cemy 50m LEGEND Track School Sch C P IE C N ROAD O O P E R S E SMOUNTAINS BLUEIN CONSTRAINTS T A OPPORTUNITIES N Site Existing vegetation U N H O E A M M E L

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m D R Ditch C 50m A G 5m Contours D FIGURE 4: SITE ANALYSIS Path

Nursery/paddocks Arbour OPPORTUNITIES Central school site CONSTRAINTS Existing vegetation Substantial bu er to settlement Memorial park 12 North Wessex Downs AONB boundary

Existing open space Potential vehicular access Overhead powerline

War memorial Potential footpath/cycle link Rear gardens

5m Contours Central school site OPPORTUNITIES CONSTRAINTS Substantial bu er to settlement Memorial park boundary North Wessex Downs AONB Potential vehicular access Overhead powerline Potential footpath/cycle link Rear gardens Central school site OPPORTUNITIES Memorial park Substantial bu er to settlement boundary

Potential vehicular access

Potential footpath/cycle link

Central school site

Memorial park Land North of Wallingford Vision Document Vision

3. VISION

To create a high quality landscape led housing development that complements Wallingford’s market town characteristics and carefully assimilates with its surrounding landscape context.

13 Land North of Wallingford Vision Document

3.1 EMERGING DEVELOPMENT CONCEPT

3.1.1 The emerging concept is based on the integration of green infrastructure, community facilities and housing into the site. There are 3 key elements to the concept:

• Transition and integration

• Protection of the AONB

• Uses and character

3.1.2 These 3 layers are illustrated to the right. s m o

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TRANSITION AND INTEGRATION

The site will function as a transitional zone between the rural and settlement edges, which currently abut one another in a crude and abrupt manner (rear property boundaries adjoining farmland). Green links will facilitate improved access to the countryside and encourage social integration between existing and proposed communities. The housing edge will extend from the settlement boundary, aiding the assimilation with the adjacent parkland. A tree lined boulevard will run east/west across the site to connect the various parcels and add a further layer of green infrastructure within the development.

14 Land North of Wallingford Vision Document

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PROTECTION OF THE AONB USES & CHARACTER

A substantial belt of undeveloped land to the north will provide a robust settlement boundary The landscaped edge will have a variety of functions that correlate with the level of activity and type and protect the setting of the adjacent AONB. Key views towards the AONB will be protected and and density of adjacent development. Land to the east will be retained for agricultural purposes, enhanced forming an integral part of the development framework. maintaining the open character and views over the AONB from Shillingford Road. Within the centre of the site, the open space will be designed with more of a community focus, incorporating a children’s play area close to the new primary school. Beyond the community focus to the north, a memorial park in commemoration to F/O. J. A Wilding and SGT. J. F Andrew, will provide a quiet reflective space with open views across the AONB. A robust landscape buffer will be provided to the north west, screening the development edge. Avenue tree planting along the access road will also minimise the impact of the development.

FIGURE 5: DESIGN CONCEPT

15 Land North of Wallingford Vision Document

3.2 EMERGING DEVELOPMENT FRAMEWORK 3.3 LAND BUDGET LEGEND

3.2.1 The emerging development framework has been designed to 3.3.1 The framework illustrated on Figure 5 can deliver the following: Site boundary maximise the site’s opportunities and respond to it’s constraints Residential block in a positive manner. The development principles embodied Residential: 9.59ha ~350 dwellings @ 35dph within the emerging masterplan are as follows: 1 FE primary school: 2.2ha Potential expansion land POS & green corridors: 7.17ha 1 Potential access off the A4130 roundabout, Wantage Road and/ 1FE primary school or Shillingford Road. (to include new Memorial Park, Childrens Play and 2 A network of green corridors provide pedestrian and cycle proposed buffer planting) Open space links to the south and west promoting social integration and Highways/access: 1.7ha enhancing connectivity. Memorial park

3 A strong woodland buffer provides a robust settlement boundary Agricultural land and reinforces the existing landscape character created by linear Total: 21.57ha tree belts along Shillingford Road and a woodland block within Retained vegetation the site. Proposed bu er planting 4 A tree lined primary street passes through both parcels of land, promoting a comprehensive masterplan approach to the Parkland / avenue trees development.

5 A primary school is situated within the centre of the site, easily Neighbourhood play area accessible from all areas within the development and the existing community to the south/south west. War memorial A neighbourhood play area is situated within a highly accessible 6 SUDS location close to the school and along the central green corridor where views over the AONB can also be appreciated. Existing road 7 Land to the north of the site is retained in agricultural use to provide an extensive development offset from the AONB. Primary street

8 An opportunity exists to provide a memorial park extending from Secondary street the neighbourhood play area to the north in commemoration to F/O. J. A Wilding and SGT. J. F Andrew. Residential street 9 Development wraps the exposed rear gardens to the south/ south west, enhancing security and creating a more attractive Mews street settlement edge. PRoW (footpath) 10 SUDS are integrated within green corridors and low lying land, promoting ecological habitat creation and a variety of landscape Footpath/cycleway features within the development. 11 A shared surface mews street provides a pedestrian friendly link Feature building through the primary residential area. A series of feature greens Vista termination building are situated along this route, adding interest and providing doorstep play opportunities and intimate community spaces. Parkland frontage 12 Two development frontage typologies are designed to respond to their immediate setting and reinforce the movement hierarchy. Primary street frontage

AONB

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17 Land North of Wallingford Vision Document

3.4 DEVELOPMENT CHARACTER

3.4.1 Two development frontage typologies (parkland and primary street) are designed to respond to their immediate setting and WOODLAND reinforce the movement hierarchy. The parkland edge typology BUFFERS would be lower density and more informal in character with a closer assimilation with the landscape. In contrast, the primary street edge will be more formal in character with a continual building line reinforced by the avenue of trees along the route.

3.4.2 Five key landscape typologies are designed to enhance the development character, promote social integration, structure views out over the AONB, aid the transition from urban edge to rural setting and create a more robust settlement boundary. The MEMORIAL typologies are as follows: PARK

• Woodland buffers: trees area used to provide interest and act as a visual buffer to screen views of development on the site, particularly planted in an east-west orientation, helping to reduce views from the rising ground to the north. Blocks of woodland trees will also be arranged as loose scatters, clumps, and perimeter belts to create views and structure the landscape. In particular, trees will be used to frame open views to the AONB countryside from areas of Wallingford to the south. GREEN • Memorial park: an area of parkland in commemoration to F/O. J. CORRIDORS A Wilding and SGT. J. F Andrew. The parkland will be designed as a quiet space for reflection on the edge of the development with open views over the AONB. The use of water, public art and informal groups of both native and exotic parkland trees will add interest and diversity to the space. Use of exotic trees as single specimens or small groups will also form statuesque features in the wider landscape.

• Green corridors: linear routes connecting the proposed NEIGHBOURHOOD development to the existing settlement and wider countryside. PLAY AREA A network of meandering swales along these routes will collect rainwater across the site and distribute to a network of balancing ponds located to the south.

• Neighbourhood play area: a formal area of parkland relating more closely to the development providing a key community facility alongside the primary school. The play area will fall within the view corridor towards the AONB and as such the equipment will be sensitively designed both in terms of scale and materials. RESIDENTIAL • Residential greens: pockets of green spaces creating areas of GREENS relief within the residential development and providing doorstep play opportunities and locations for larger specimen trees. The semi-private nature of these spaces will engender a communal sense of ‘ownership’ and encourage social interaction. 18

Land at North

Define | Unit 6 133-137 Newhall Street | Birmingham | B3 1SF T: 0121 2371914 W: www.wearedefine.com

Land North of Wilding Road

Review of the Strategic Environmental Assessment supporting the Wallingford Neighbourhood Plan

October 2019

Land North of Wilding Road

Review of the Strategic Environmental Assessment supporting the Wallingford Neighbourhood Plan

Project Ref: 24709/A5/EIASEA Status: Draft for input Final Issue/Rev: 01 02 Date: October 2019 October 2019 Prepared by: JM, BK JM, BK Checked by: LW LW

Barton Willmore LLP 7 Soho Square London W1D 3QB

Tel: 020 7446 6888

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

1.0 Introduction

1.1 This report sets out the conclusions of a review of the Strategic Environmental Assessment (SEA) environmental report supporting the Wallingford Neighbourhood Plan (WNP). The SEA was prepared by AECOM Limited in 2019 on behalf of Wallingford Town Council (Neighbourhood Plan Steering Group) and published alongside the draft pre-submission version of the WNP, under Regulation 14 of the Neighbourhood Planning Regulations (2012, as amended). Where a Neighbourhood Plan is likely to have significant environmental effects, a SEA needs to be carried out and an environmental report prepared in accordance with paragraphs (2) and (3) of regulation 12 of the Environmental Assessment of Plans and Programmes Regulations 2004. The full review is included at Appendix 1. It uses a ‘traffic light’ scoring system to identify areas that would benefit from improvement (amber) and those elements of the SEA process that are considered to comply fully with the requirements (green). No areas of major deficiency were identified in the SEA (red).

1.2 In addition, this report includes an appraisal of the potential development site ‘Land North of Wilding Road’ (Site A1), which is not proposed for development in the latest consultation of the WNP. The site appraisal has been undertaken by Barton Willmore, utilising the thirteen SEA Framework Objectives used to consider the alternative site options within the WNP SEA. The site-specific appraisal is included at Appendix 2 and is in matrix form with a colour coded key, a method often used for the assessment of site options in SEAs, to make the comparison of the positive and negative sustainability aspects of a site clear and consistent. This clarity of scoring is lacking in the SEA.

2.0 Review Summary:

2.1 The SEA review and site appraisal identified some areas of weakness in the SEA and site selection process that would benefit from additional consideration. These include:

Reasonable alternatives – the assessment of the site options is not always fair and consistent. Discussion around the alternatives is mostly qualitative, which makes it difficult to consistently compare the negative and positive impacts of each site for each SEA objective. As highlighted in the compliance review, excluding Site A from consideration through the SEA process is flawed as part of the Council’s reasoning for discounting this site was on mineral safeguarding grounds, which is not an environmental issue falling into the scope of SEA. Alternatives and various options for growth should have been looked at objectively in light of the full suite of environmental issued; Mitigation – mitigation has not been implemented consistently for all site options. It is therefore unknown whether an option would present a better alternative with mitigation considered. For example, an acknowledged constraint of Site A is that it is not within easy reach of facilities, however Site E which is allocated is similarly distant from the centre and described as not within convenient walking distance of the town centre and facilities. Site E is actually further to the Wallingford school secondary school, which is north of the town centre, nearer to Site A. The assessment of Site E includes mitigation in the form of a pedestrian/cycle link to be provided to the centre, however the same considerations were not given for Site A. It should also be noted that a report commissioned for Site A demonstrates that the minerals resource is not commercially extractable, and a previous Environmental Statement prepared for the site concludes that there would be no likely significant effects on air quality. This raises questions regarding the robustness of selecting the chosen site allocation; and Likely significant effects on the environment (cumulative effects) – the methodology explaining how secondary, cumulative or synergistic effects have been assessed and the conclusions from the assessment is not outlined. Furthermore, cumulative effects of the Plan as a whole (cumulative effects of multiple policies and plans) are not considered.

3.0 Site Appraisal:

3.1 The site at Land North of Wilding Road performed well overall in the assessment against the thirteen SEA Objectives. The site is sustainably located in proximity to local facilities and the public transport network and will provide new green infrastructure and enhance pedestrian and

cycling routes, providing benefits in relation to several objectives, including climate change and health.

3.2 The site will provide a minor benefit in three categories (Landscape and Historic Environment, Land soil and water resources, Population and community) and major benefits in another three categories (Climate change, population and community (2), health and wellbeing). Neutral scores were awarded for land, soil and water resources with regards to waste, air quality, as well as landscape and historic environment relating to landscape character. The full appraisal is included at Appendix 2.

3.3 The conclusion reached within this report, based on the SEA review in Appendix 1 and the site appraisal in Appendix 2, is that the site Land North of Wilding Road presents a reasonable preferred option for sustainable development and could have equally been considered for inclusion in the chosen allocation within the WNP, when compared to the other sites.

Appendix 1 Strategic Environmental Assessment Compliance Review Appendix 2 Site Appraisal Land North of Wilding Road

APPENDIX 1: STRATEGIC ENVIRONMENTAL ASSESSMENT COMPLIANCE REVIEW

Compliance Notes Key This is not a legal review. Where a Neighbourhood Plan is Meets requirements likely to have significant environmental effects, a SEA needs to be carried out and an environmental report prepared in accordance with paragraphs (2) and (3) of regulation 12 of Improvements suggested the Environmental Assessment of Plans and Programmes Regulations 2004. The following reports have been considered: Risk of challenge. Does not meet requirements

Aug 2019 WNP Site Assessment Document (2019 Site Assessment Document); Aug 2019 Strategic Environmental Assessment (SEA) for the Wallingford Neighbourhood Plan Environmental Report (herein referred to as the 2019 SEA), published alongside the draft pre-submission version of the WNP, under Regulation 14 of the Neighbourhood Planning Regulations (2012, as amended).

SEA Regulations, Regulation 12 and Schedule 2 - Contents of Environmental Report

1. An outline of the contents and main objectives of the plan Covered in Sections 2 and 3, Table 3.1 of the 2019 SEA. or programme, and of its relationship with other relevant plans and programmes. Sections 2 and 9 of the 2019 SEA contain a review of relevant policy and how the WNP interacts with different policies and plans.

2. The relevant aspects of the current state of the Covered in Appendix II of the 2019 SEA. Contains key issues for the WNP area under each of the SEA environment and the likely evolution thereof without assessment framework topic headings. implementation of the plan or programme. There is no summary of likely evolution of the environment without the Plan.

3. The environmental characteristics of areas likely to be Covered in Appendix II of the 2019 SEA. significantly affected For Neighbourhood Plans there should be a site level of detail, including constraints maps. These have not been presented for the site assessments, but this is not a serious deficiency

4. Any existing environmental problems which are relevant to Section 9.8 of the 2019 SEA acknowledges the protection afforded to European designated ecological sites the plan or programme including, in particular, those relating (e.g. Little Wittenham Special Area of Conservation (SAC)) by the Habitats Regulations and the requirement to any areas of a particular environmental importance, such to undertake a HRA to ascertain the potential for adverse effects on the integrity of European sites. It also as areas designated pursuant to Council Directive outlines policy mitigation; however, it is not summarised in relation to the site options. Section 9.37 – 9.40

79/409/EEC on the conservation of wild birds(a) and the of the 2019 SEA does not outline the HRA conclusions with respect to site allocation and decision making or Habitats Directive. define what this has been assessed ‘in combination’ with (other sites, plans, environmental effects).

5. The environmental protection objectives, established at The SEA framework is covered within Chapter 3 and Table 3.1 and the context review is presented within international, Community or Member State level, which are Appendix II of the 2019 SEA. relevant to the plan or programme and the way those objectives and any environmental considerations have been Assessment against the objectives covered in Section 9 of the 2019 SEA. taken into account during its preparation.

6. The likely significant effects on the environment, including Covered in Section 9 of the 2019 SEA and the 2019 Site Assessment Document. short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and The 2019 Site Assessment Document does not appraise each of the site options against the objectives in secondary, cumulative and synergistic effects, on issues such the SEA Framework in a matrix, and therefore does not consistently highlight the negative and positive as— impacts of each site for each objective. Instead the review is mostly qualitative, which means it is difficult (a) biodiversity; to compare sites at this stage, and to determine how/why they have been discounted or chosen for (b) population; allocation. (c) human health; (d) fauna; The approach to the assessment of cumulative effects is not well outlined. Secondary, cumulative or (e) flora; synergistic effects are not assessed throughout the 2019 SEA. The SEA should include methodology (f) soil; explaining how these have been assessed and the conclusions from the assessment of effects. In addition, (g) water; cumulative effects of the Plan as a whole (cumulative effects of multiple policies and plans) are not (h) air; considered. (i) climatic factors; (j) material assets; Section 9.37 of the 2019 SEA – conclusions at this current stage, describes only positive impacts relating to (k) cultural heritage, including architectural and the preferred option, but does not mention the air quality issues and accessibility issues assessed for this archaeological heritage; option in the 2019 Site Assessment Document. The conclusion states Option E will have a positive effect on (l) landscape; and accessibility to services, facilities and public transport networks, traffic and congestion issues, which will (m) the inter-relationship between the issues referred to in also lead to indirect positive effects in relation to the ‘air quality’ SEA theme. However, this contradicts the sub-paragraphs (a) to (l). 2019 Site Assessment Document which suggests that not all Site E is within convenient walking distance of the town centre and facilities, and Site E is actually further to the Wallingford school secondary school.

7. The measures envisaged to prevent, reduce and as fully Some mitigation for the overall WNP area in policy in Section 9 of the 2019 SEA. as possible offset any significant adverse effects on the environment of implementing the plan or programme. Mitigation is not covered well in the 2019 Site Assessment Document. No measures are proposed or considered for the potential impacts and constraints identified for each alternative site option. It is not clear how the mitigation for the plan is considered in the site assessments, and how they can vary if the plan mitigation applies to all. e.g. air quality issues identified for Site A could be mitigated using best practice measures and improving access to more sustainable modes of public transport, and the provision of the school, however this is not considered. 8. An outline of the reasons for selecting the alternatives Covered in Sections 4 and 5 of the 2019 SEA which outline how site options potentially in contention for dealt with, and a description of how the assessment was allocation were developed and assessed. undertaken including any difficulties (such as technical

deficiencies or lack of know-how) encountered in compiling It is concerning that the SEA Report justifies excluding Site A from further consideration due to a minerals the required information. safeguarding allocation. Minerals safeguarding is not an environmental issue, does not fall within the remit of SEA or feature in any of the SEA objectives. Whilst it is acknowledged that the Council advised their consultants to exclude Site A from further consideration on this basis, it is reasonable to expect that the SEA should have taken account of alternatives based on environmental issues only. Without this, the Neighbourhood Plan cannot be said to be environmentally led.

The discussion around alternatives could be made clearer and be more evidence based to provide clarity on why the WNP is a reasonable strategy in terms of environmental impact and include additional justification for the alternative sites considered. References are not given to the evidence base supporting alternatives e.g Scoping report, preferred options.

The SEA is lacking a clear timeline of the plan-making and SEA process to show that the process has been iterative. Figure 5.2 of the 2019 SEA shows a location plan of the alternatives considered and paragraph 5.16 outlines the two reasonable scenarios.

Site A was discounted on the fact it is not within easy reach of facilities within the town centre, however Site E which is allocated is similarly distant from the centre – states not all the site is within convenient walking distance of the town centre and facilities, and Site E is actually further to the Wallingford school secondary school, which is north of the town centre, nearer to Site A. The assessment of Site E includes mitigation in the form of a pedestrian/cycle link to be provided to Brookmead Drive to the centre, however the same considerations were not given for Site A. Site E will also impact traffic movement in the town and exacerbate AQ issues in the AQMA.

Post-mitigation assessments were not undertaken for each of the site options. It is therefore unknown whether an option would present a better alternative with mitigation considered, than the other options with mitigation. More justification is needed as to why sites were discounted without more details and including mitigation being taken into account.

Also, Site E states LVIA will minimise harm to the AONB and the Conservation Area, but does not suggest the same measures for Site A, which would make the impacts less significant.

It would be helpful to include more justification and method within the SEA for the reasoning behind site assessment, as it raises questions regarding the robustness of selecting the chosen site allocation. In doing so, other combinations of sites should be considered such as the allocat5ion of Sites C and E, with the additional allocation of Site A.

There is no discussion within the 2019 SEA of the limitations of predicting effects or assumptions made about secondary data and the accuracy of publicly available information for topic specific assessments. This would help explain the brevity of explanation provided when certain judgments are made. 9. A description of the measures envisaged concerning Covered in Section 12 of the 2019 SEA, however this could be much stronger. No methodology, measures monitoring in accordance with regulation 17. or timeline for carrying out the monitoring is proposed, and no monitoring indicators are provided for topics appraised in the SEA.

10. A non-technical summary of the information provided Appendix 1 Table C states that the NTS is a separate document, however there is no reference or link to under paragraphs 1 to 9. this, which would be helpful.

APPENDIX 2: SITE APPRAISAL OF LAND NORTH OF WILDING ROAD

NB. This is the Applicant’s own key, Compliance Key Notes which does not feature in the SEA. ++ Positive Strong Evidence

+ Positive Weak Evidence

0 Neutral or No Impact

- Negative Weak Evidence

-- Negative Strong Evidence

SEA Objective Appraisal Indicators Score Justification

Air Quality: Will the option/proposal help to: 0 The Wallingford AQMA is situated to the South of the site. The AQMA covers Improve air quality in the an area extending from either side of Wallingford High Street from just west Wallingford Neighbourhood Plan • Support a reduction of the emissions which led of Wallingford Bridge to the junction with Croft Road/St Georges Road. The area and minimise and/or mitigate to the designation of the Wallingford Air Quality southern edge of the site is approximately 550 metres from the centre of against all sources of environmental Management Area? the AQMA. pollution. • Promote the use of sustainable modes of Public transport is accessible within 400m of the site, providing many transport, including walking, cycling and public options for more sustainable travel. There are bus services every half hour transport? running from Oxford to Wallingford, passing major towns such as Abingdon, Milton Park and Didcot. The development could support the expansion of • Implement measures (such as appropriate routes in this area, especially to serve the proposed primary school. Railway planting and provision of green infrastructure) stations at Cholsey (approximately 4 miles away) and Didcot Parkway which will help support air quality in the (approximately 5.4 miles away) provide further direct connections to Neighbourhood Plan area? Reading and London Paddington.

The need for travel is reduced through the co-location of a primary school and residential use, with other facilities located within Wallingford also in walking distance. These facilities include local shops, amenities, medical practices and leisure establishments. Wallingford town centre is situated approximately 1 kilometre from the Site.

The creation of woodland buffers offers opportunities for the sequestration of emissions which in turn help to improve air quality. The Memorial Park would also aid in the regulation of air quality.

The site’s separation from Wallingford Town Centre when coupled with the prevailing wind direction that would blow traffic emissions away from the site, mean that local air quality will not cause significant design constraints for the proposed development.

Furthermore, a previous Environmental Statement prepared for the Site found that effects on air quality at the site pre-mitigation would range from ‘negligible’ to ‘minor adverse’. With mitigation efforts, effects on air quality would be negligible.

Biodiversity and Geodiversity: Will the option/proposal help to: + The site does not fall within any ecological destinations. There are no SACs, Protect and enhance all biodiversity SPAs, SSSIs, Ramsar sites within approximately 2.5 kilometres of the and geological features. • Protect and enhance semi-natural habitats? boundary.

• Protect and enhance priority habitats, and the Beech tree planting along the southern half of the eastern boundary will habitat of priority species? allow for an increase in the species richness and evenness at the site, thus helping to achieve a net gain in biodiversity when compared with the • Achieve a net gain in biodiversity? baseline of no development. Hedgerows of ecological value are to be maintained, with agricultural land which offers little biodiversity value is to • Support enhancements to multifunctional green be displaced. The area to the northern boundary of the site will act as a no- infrastructure networks? development zone, creating a buffer and a wildlife corridor to promote the joining up of habitats. A tree lined boulevard will run east/west across the • Support access to, interpretation and site to connect the various parcels and add a further layer of green understanding of biodiversity and geodiversity? infrastructure within the development.

Tree planting to the effect of promoting green infrastructure within the settlement will enhance semi-natural biodiversity values. In turn, this will benefit human health and well-being, owing to the provision of an accessible natural environment for the local population. Climate Change: Will the option/proposal help to: 0 Public transport is accessible within 400m of the site, providing a choice of Reduce the level of contribution to more sustainable transport modes. There are bus services every half hour climate change made by activities • Reduce the number of journeys made? running from Oxford to Wallingford, passing major towns such as Abingdon, within the Neighbourhood Plan area Milton Park and Didcot. The development could support the expansion of • Reduce the need to travel? routes in this area, especially to serve the proposed primary school. Railway stations at Cholsey (approximately 4 miles away) and Didcot Parkway • Promote the use of sustainable modes of (approximately 5.4 miles away) provide further direct connections to transport, including walking, cycling and public Reading and London Paddington. transport? The need for travel is reduced through the provision of the primary school, • Increase the number of new developments with other facilities located within Wallingford also in walking distance. meeting or exceeding sustainable design criteria? These facilities include local shops, amenities, medical practices and leisure

• Generate energy from low or zero carbon establishments. Wallingford town centre is situated approximately 1 sources? kilometre from the site.

• Reduce energy consumption from non- The site promotes the use of walking and cycling through existing renewable resources? connections which run through Wallingford, including: the recreational route which runs along the western side of the Thames, located to the East of the Site; a public right of way to the North of the site past Sotwell Hill and a bridleway to the north-west.

Climate Change: Will the option/proposal help to: ++ The site is located entirely within Flood Zone 1 and therefore has a very low Support the resilience of the risk of flooding from the River Thames, which is situated approximately 1.3km Neighbourhood Plan area to the • Ensure that inappropriate development does not to the East of the site. potential effects of climate change, takes place in areas at higher risk of flooding, including flooding taking into account the likely future effects of SUDS are proposed to be integrated within green corridors and low-lying climate change? land to mitigate this risk. Green corridors connecting the proposed development to the existing settlement and wider countryside will also act • Improve and extend green infrastructure as a distributing network to balancing ponds located to the South. networks in the plan area to support adaptation to This also helps to promote increased biodiversity within the immediate area the potential effects of climate change? through a mixture of species, that underpins biodiversity resilience. Woodland buffers used to delineate the adjacent AONB also reduce the potential for • Sustainably manage water run-off, reducing flooding within the site. surface water runoff (either within the plan area or downstream)?

• Ensure the potential risks associated with climate change are considered through new development in the Neighbourhood Plan area?

• Increase the resilience of biodiversity in the area to the effects of climate change, including through enhancements to ecological networks?

Landscape and historic Will the option/proposal help to: + There are no designated archaeological assets on the site and none in the environment: immediate vicinity of the site. Protect, maintain and enhance the • Conserve and enhance buildings and structures cultural heritage resource within the of architectural or historic interest? An archaeological Desk-Based Assessment (DBA) has been undertaken, Neighbourhood Plan area, including which found no over-riding archaeological constraints to development. The the historic environment and • Conserve and enhance the setting of the Oxfordshire Historic Environment Record (HER) does not record any archaeological assets. Wallingford Conservation Area? archaeological assets on the site, although a modest potential for features associated with Later Prehistoric occupation and agricultural activity is • Support the integrity of the historic setting of identified. There is a low archaeological potential for all other evidence. key buildings and features of cultural heritage interest? A war memorial lies adjacent to the south of the site. The site lies approximately 500m North-West of the Monument, with no direct inter • Conserve and enhance local diversity and visibility between the site and the Monument due to the barrier of the urban character? environment. Owing to both the distance and lack of visibility, the proposed development will not impact the setting of the Monuments. • Support access to, interpretation and The development will therefore not have any significant impact on any understanding of the historic environment? nationally important archaeological assets.

There is potential to facilitate the interpretation and understanding of the historic environment through key footpath routes leading to the proposed development from the centre of Wallingford. These would bring residents into close proximity with the historic environment, encouraging appreciation of these built forms.

The site is not located within a conservation area and therefore, no effects are anticipated. The conservation area is located approximately 500 metres to the south-east of the site. Landscape and historic Will the option/proposal help to: 0 environment: The North Wessex Downs AONB encircles the site to the north and east with Protect and enhance the character • Support landscape character reflecting the open, expansive landscapes and little vegetation cover. A substantial belt of and quality of landscapes and sensitivities of the four landscape types covering undeveloped land to the North will provide a robust settlement buffer and townscapes. the Neighbourhood Plan area? protect the setting of the adjacent AONB. In effect, this would blur the transitional zone from rural areas to the outskirts of Wallingford. • Conserve and enhance landscape and townscape features? Restricting building heights to two storeys ensure that the landscape character will be preserved when combined with the tree provision.

Land, soil and water resources: Will the option/proposal help to: - The site is greenfield and has not been previously developed. Ensure the efficient and effective use of land. • Promote the use of previously developed land? The Wallingford Neighbourhood Plan Site Assessment Document identifies that the Site (Site A) is in agricultural use Grades 1-3. • Avoid the development of the best and most versatile agricultural land, which in the Neighbourhood Plan area may comprise Grade 1, 2 and 3a agricultural land?

Land, soil and water resources: Will the option/proposal help to: 0 There would likely be minimal demolition waste due to the undeveloped Promote sustainable waste nature of the site. Any construction waste would be dealt with appropriately management solutions that • Reduce the amount of waste produced? in accordance with LPA requirements and all applicable legislation. encourage the reduction, re-use Consideration would be given to responsible sourcing and use of recycled and recycling of waste. • Support the minimisation, reuse and recycling of materials, where practicable. waste? Appropriate provision for domestic waste and recycling facilities would be included in the design. Waste and recycling would be collected by the LPA’s • Maximise opportunities for local management of normal domestic collection service. waste in order to minimise export of waste to areas outside?

• Encourage recycling of materials and minimise consumption of resources during construction? Land, soil and water resources: Will the option/proposal help to: + The site is underlain by a Principal Aquifer with intermediate vulnerability. Use and manage water resources in Therefore, the aquifer underlying the site only supplies water at a local scale a sustainable manner. • Support improvements to water quality? but is vulnerable to contaminants from the soil surface. This is reflected in considerations within the drainage strategy. • Minimise water consumption? This drainage strategy will include infiltration techniques identified as • Protect sensitive groundwater resources in the suitable for the location as well as source control SuDS such as water butts Neighbourhood Plan area? and permeable paving will also be considered. This is in conjunction with vegetation that serves within the SuDS through slowing infiltration but also provides ecological and amenity benefits. This includes a permanently wet area which will be incorporated into some or all of the infiltration basins for ecological benefits.

Population and Community: Will the option/proposal help to: + The proposal includes a new 2 Form Entry (FE) primary school. This would Cater for existing and future be centrally located within the site, adjacent to new areas of open space. residents’ needs as well as the • Promote the development of a range of high Easily accessible, public transport, walking etc? In proximity to leisure, needs of different groups in the quality, accessible community facilities? community facilities and new areas of open space? community, and improve access to local, high-quality community • Encourage and promote social cohesion and The school is to be accessed through both new and existing walking and services and facilities. encourage active involvement of local people in cycling routes. These include from the south to the existing bulk of community activities? Wallingford. Approximately 500m to the south-east of the site is Wallingford Secondary School, which already serves the community. Reduce deprivation and promote a • Minimise fuel poverty? more inclusive and self-contained Existing areas of green spaces will be converted into a neighbourhood play community • Maintain or enhance the quality of life of existing area, creating a formal area of parkland. This is in conjunction with the local residents? primary school. The parkland has potential to improve or at the very least, maintain visual amenities through providing view corridors on towards the • Improve the availability and accessibility of key AONB. Furthermore, enhancements to green infrastructure in the form of local facilities, including specialist services for residential greens situated to facilitate social interactions and foster disabled and older people? communal ownership allow for improvements to quality of life.

• Support the provision of land for allotments and cemeteries? Population and community: Will the option/proposal help to: ++ The proposed development offers approximately 9.6 ha of residential Provide everyone with the development area. A neighbourhood of approximately 350 homes will opportunity to live in good quality, • Support the provision of a range of house types achieve a traditional residential density approach (35 dwellings per hectare), affordable housing, and ensure an and sizes? capable of contributing to the objectively assessed housing requirements of appropriate mix of dwelling sizes, Oxfordshire. types and tenures. • Support enhancements to the current housing stock? Two development frontage typologies (parkland and primary street) are designed to respond to their immediate setting and reinforce the movement • Meet the needs of all sectors of the community? hierarchy. This would also include a mix of affordable housing and starter homes. • Provide quality and flexible homes that meet people’s needs? Houses would be built utilising best practice and best available technologies.

• Promote the use of sustainable building The need for travel is reduced through the provision of the primary school, techniques, including use of sustainable building with other facilities located within Wallingford also in walking distance. materials in construction? These facilities include local shops, amenities, medical practices and leisure establishments. Wallingford town centre is situated approximately 1 • Provide housing in sustainable locations that kilometre from the Site. allow easy access to a range of local services and facilities?

Health and Wellbeing: Will the option/proposal help to: ++ Leisure facilities in proximity to the site include: a Memorial Park; Green Improve the health and wellbeing Corridors and woodland buffers. There are several leisure centres located residents within the Neighbourhood • Promote accessibility to a range of leisure, within a two kilometre radius, including Wallingford Sports Park and Plan area health and community facilities, for all age Riverside Park and Pools. groups? Accessibility to health facilities are promoted through sustainable means of • Provide and enhance the provision of community travel and can be accessed on foot. These include Wallingford Community access to green infrastructure, in accordance with Hospital approximately 1.25km from the site, Wallingford House Dental Accessible Natural Greenspace Standards? Practice approximately 800 metres away and an Opticians also approximately 800 metres away. • Reduce noise pollution? The delivery of 350 homes could lead to increases in noise associated with • Promote the use of healthier modes of travel? vehicular transport. The primary noise sources are the local roads especially through the west boundary of the Site along Wantage Road. • Improve access to the countryside for A Construction Environmental Management Plan (CEMP) will be prepared in recreational use? agreement with the LPA before the commencement of works in accordance with best practice measure and appropriate legislation, to reduce the risk of pollution incidences during construction. In addition, the CEMP will implement measures to reduce noise impacts to the area during construction of the development. These mitigation measures may be implemented in the form of tree-planting offers a natural noise barrier distinguishing the proposed settlement to the existing core of Wallingford. Sensitive uses such as the primary school will be located in the quieter areas of the site, as well as the memorial park to the effect that noise would not disrupt their usage.

Access to the countryside for recreational use is improved through the provision of new walkways acting as buffers within the development. The memorial park would act as an area of parkland, uniting aspects of the natural and historic environment together for recreational usages. Maintaining aspects of agricultural land provide the basis for interactions with the countryside and a rural lifestyle.

Green links will facilitate improved access to the countryside and encourage social integration between existing and proposed communities.

Transportation: Will the option/proposal help to: - Potential vehicular access to the site could be provided off the A4310 Promote sustainable transport use roundabout, Wantage Road and/or Shillingford Road. An increased number and reduce the need to travel. • Encourage modal shift to more sustainable of people will lead to more people using the road network which in turn forms of travel? could lead to higher levels of congestion. The Wallingford AQMA is situated to the South of the Site. The AQMA covers an area extending from either • Enable sustainable transport infrastructure side of Wallingford High Street from just west of Wallingford Bridge to the enhancements? junction with Croft Road/St Georges Road. The southern edge of the Site is approximately 550 metres from the centre of the AQMA. • Facilitate working from home and remote working? Public transport is accessible within 400m of the site, providing a variety • Improve road safety? options for travel. There are bus services every half hour running from Oxford to Wallingford, passing major towns such as Abingdon, Milton Park • Reduce the impact on residents from the road and Didcot. The development could support the expansion of public network? transport routes in this area, especially to serve the proposed primary school. Railway stations at Cholsey (approximately 4 miles away) and Didcot Parkway (approximately 5.4 miles away) provide further direct connections to Reading and London Paddington.

Local amenities can easily be reached by foot from the site and there is provision of improved cycle networks spanning the site to encourage a multi-modal culture of travel.

GALLAGHER ESTATES LIMITED

PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD

GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

SEPTEMBER 2018

GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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BM11216 SEPTEMBER 2018

Wardell Armstrong Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom Telephone: +44 (0)1782 276700 www.wardell-armstrong.com

DATE ISSUED: September 2018 JOB NUMBER: BM11216 REPORT NUMBER: 02

GALLAGHER ESTATES LIMITED

PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD

GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

SEPTEMBER 2018

PREPARED & APPROVED BY:

Stephen Barry Technical Director

This report has been prepared by Wardell Armstrong LLP with all reasonable skill, care and diligence, within the terms of the Contract with the Client. The report is confidential to the Client and Wardell Armstrong LLP accepts no responsibility of whatever nature to third parties to whom this report may be made known.

No part of this document may be reproduced without the prior written approval of Wardell Armstrong LLP.

ENERGY AND CLIMATE CHANGE ENVIRONMENT AND SUSTAINABILITY INFRASTRUCTURE AND UTILITIES Wardell Armstrong is the trading name of Wardell Armstrong LLP, Registered in England No. OC307138. LAND AND PROPERTY

Registered office: Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom MINING AND MINERAL PROCESSING MINERAL ESTATES UK Offices: Stoke-on-Trent, Birmingham, Cardiff, Carlisle, Edinburgh, Glasgow, Greater Manchester, Central Manchester, London, Newcastle upon Tyne, Sheffield, and Truro. International Offices: Almaty and Moscow . WASTE RESOURCE MANAGEMENT

GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

CONTENTS EXECUTIVE SUMMARY ...... 1 1 Introduction ...... 2 2 GEOLOGY ...... 2 3 MINERAL PLANNING ...... 3 4 VIABILITY & FEASIBILITY OF MINERAL EXTRACTION ...... 4 5 CONCLUSION ...... 5

APPENDICES Appendix 1 Logs of boreholes 1 to 9

DRAWING BM11216-011 Extent of Site Investigation Works

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EXECUTIVE SUMMARY

This report has been prepared in support of representations to be submitted to the “Issues and Options Consultation” on Part 2 of the Oxfordshire Minerals and Waste Local Plan. The representations relate to a proposed development site at Wallingford.

The superficial deposits on the site comprise sand and gravel deposits that have been identified as a Mineral Safeguarding Area (MSA) by Oxfordshire County Council (OCC) in its Minerals and Waste Local Plan. The published geological plans for the area show that the site is covered with river terrace deposits comprising sand and gravel of the Summertown-Radley Member, which is the safeguarded resource. An intrusive site investigation conducted by Wardell Armstrong showed the deposit to be less than 2m thick with an average overburden thickness of 0.5m.

This report demonstrates that the site does not contain commercially viable minerals because the sand and gravel includes a high proportion of silt (which is a contaminant), a high proportion of sand (which is of limited use and low value) and a low proportion of gravel (which is the useful and more valuable component). Furthermore, the site is too close to residential properties for mineral extraction to be acceptable in terms of amenity, so realistically it would never be worked.

The evidence in this report shows that the economic considerations relating to the mineral resource demonstrate that the mineral deposit is of no commercial use or interest, so the mineral would never be worked in any event. It is clear that the proposed development would be consistent with the County Council’s adopted planning policy relating to mineral safeguarding. Consequently, the imposition of a MSA designation on the site is not necessary.

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GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

1 INTRODUCTION

1.1 This report has been commissioned by Gallagher Estates Limited in support of representations to be submitted as a response to the publication of the “Issues and Options Consultation on the Oxfordshire Minerals and Waste Local Plan Part 2- Site Allocations”. The representations relate to the site of a proposed residential development at Wallingford, Oxfordshire, approximately 15 km south of Oxford. We understand that the site is currently in agricultural use.

1.2 The site is shown edged red on drawing No. BM11216-011 and is located to the north of Wallingford. The site is bounded by agricultural land to the north and east, and existing residential development to the south and west. It is in an area that Oxfordshire County Council (OCC) has identified as a Mineral Safeguarding Area (MSA) for sand and gravel in Part 1 of its adopted Minerals and Waste Local Plan.

2 GEOLOGY

2.1 Geologically, a distinction is made between “superficial deposits” and “solid geology”. Superficial deposits such as sand and gravel are found at, or close to, the surface. The solid bedrock beneath the superficial deposits is called the “solid geology”.

Superficial Deposits

2.2 The British Geological Survey (BGS) online geological plans at 1:50,000 scale indicate that the site is underlain by river terrace sand and gravel of the Summertown-Radley Member.

2.3 In June 2017, Wardell Armstrong completed an intrusive investigation at the site comprising nine boreholes and four trial pits. Five of the nine boreholes reached the base of the deposit. Borehole and trial pit logs are attached at . The locations of intrusive investigations are shown on drawing no. BM11216-011. Sand and gravel at the site is shown to be less than 2.0m thick, with an average overburden thickness of 0.5m. The borehole logs generally describe the deposits as “medium to coarse clayey gravelly sand”.

2.4 Sand and gravel deposits are of commercial interest in certain circumstances, providing that they have a high proportion of gravel, with a low proportion of silt and clay, and are large enough to justify the substantial investment necessary to recover and process the mineral. Particle size distribution (PSD) analyses (conforming to

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BS1377-2 1990) have been undertaken. The grading analysis shows the deposit to have a high proportion of fines (averaging 17%) and a low proportion of gravel (averaging 32%). Clay and silt (collectively called “fines”) are contaminants which can be difficult to remove and usually render a deposit uneconomic when present as more than 15% of the deposit.

Solid Geology

2.5 Published geological mapping indicates the site to be underlain by siltstones and sandstones of the Upper Greensand Formation. These beds are not of commercial interest and are not safeguarded.

3 MINERAL PLANNING

3.1 The site is located in the administrative area of Oxfordshire County Council (OCC) which is the Mineral Planning Authority (MPA) for the area.

3.2 The current planning policy for mineral development in Oxfordshire is contained in the Oxfordshire Minerals and Waste Local Plan (2017) which is being prepared in two parts. Part 1 is the Core Strategy which was adopted on 12 th September 2017 and covers the period through to 2031. Part 2 is the Site Allocations Plan, which will identify MSAs in detail. The publication of the Issues and Options Consultation document in August 2018 is the start of the evolution of Part 2 of the Minerals and Waste Local Plan.

3.3 The Core Strategy sets out the vision, objectives, spatial planning strategy and policies for meeting development requirements for the supply of minerals and the management of waste in Oxfordshire over the period to 2031. It provides a policy framework for identifying sites for new minerals and waste developments in Part 2 of the plan (the “Site Allocations Document”) and for making decisions on planning applications.

3.4 Mineral Safeguarding Areas are defined on the Policies Map which accompanies the Plan. The Policies Map also shows the location of “mineral strategic resource areas” which are identified in policy M3. The site is located within Strategic Resource Area No.5 – Thames and the Lower Thame Valleys – Standlake to Yarnton.

3.5 The consultation paper includes Issue 8 which relates to mineral safeguarding. Issue 8 states that the mineral safeguarding areas are currently limited to the strategic

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GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

resource areas in policy M3 and some other large areas of sharp sand and gravel resource. It notes that geological mapping shows other areas of mineral resource in the county where potentially workable minerals may exist but they are not safeguarded. It states that preparation of the Sites Plan may provide an opportunity to review the existing MSAs and if appropriate, add additional areas of mineral resource to the MSAs.

3.6 Accordingly, Question 16 in Issue 8 asks “Should the mineral safeguarding areas be reviewed and, if appropriate, amended to include other areas of mineral resource?” However, it may assist other forms of non-mineral development if the review were also to identify parts of identified MSAs where a proposed development site meets the policy criteria to be acceptable in a MSA.

3.7 The mineral planning Policy M8 provides that incompatible development will not be permitted in Mineral Safeguarding Areas unless one of the following three conditions is satisfied:

• the site is allocated for development in an adopted local plan or neighbourhood plan;

• the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; or

• the mineral will be extracted prior to the development taking place.

3.8 The following section of this report examines the economic considerations associated with this mineral deposit.

4 VIABILITY & FEASIBILITY OF MINERAL EXTRACTION

4.1 Intrusive investigation of sand and gravel deposits at the site indicates that the superficial deposits are not of satisfactory commercial quality for use as an aggregate because they contain a high proportion of silt and clay (which are contaminants) and a low proportion of gravel. Furthermore, the sand and gravel is less than 2m thick, which is too thin to be of commercial interest.

4.2 The sand and gravel deposits are also subject to pre-existing indirect sterilisation due to the presence of existing residential properties adjacent to the south and west boundaries of the site. The proximity of these properties means that mineral

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GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

extraction could not be undertaken because it would have an unacceptable impact on the amenity of the residents in those properties.

4.3 Prior extraction is not a practicable proposition. Sand and gravel is not usually used in its as-dug condition and it is usually screened and washed to remove contaminants and crushed to create a processed aggregate that meets construction industry standards. The sand and gravel is described as clayey with an average of 17% silt and 32% gravel. These proportions of high silt content and low gravel content indicate that the deposit would not be commercially viable.

5 CONCLUSION

5.1 This report has demonstrated that this site contains a thin deposit of sand and gravel comprising a high proportion of fines, a high proportion of sand, and a low proportion of gravel. These characteristics show that the sand and gravel on the site is not of acceptable commercial quality or value, which constitutes the economic considerations that are mentioned in the adopted planning policy relating to mineral safeguarding. In summary, the mineral is not a commercially viable deposit, so it has no economic value and consequently prior extraction is not feasible. Furthermore, the deposit is already indirectly sterilised due to the proximity of residential development, so in practice it will never be worked.

5.2 In the light of this evidence, we consider that the economic considerations relating to the mineral on the site mean that the sand and gravel is of no economic or practical significance. It therefore appears that the benefit of any alternative land use, including the need for the proposed development, would outweigh the economic and sustainability considerations relating to the mineral resource. Consequently, the proposed development would be compliant with adopted mineral safeguarding policy and the MSA designation on the site is not necessary.

BM11216 Page 5 SEPTEMBER 2018

Appendix 1

Logs of boreholes 1 to 9

GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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BM11216 SEPTEMBER 2018

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$ ,4 ) $5 6 GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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BM11216 SEPTEMBER 2018

DRAWINGS

GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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BM11216 SEPTEMBER 2018

KEY

Trial Pit ¯ Windowless Sampling Borehole

WS5 Red Line Boundary

SA2

SA1

WS15 WS10

WS6 WS7 Notes:

REVISION DETAILS DATE DRAWN CHK'D APP'D

CLIENT

GALLAGHER ESTATES LIMITED WS9 WS11

PROJECT

WS12 LAND NORTH OF WILDING ROAD, WALLINGFORD

DRAWING TITLE

WS8 EXTENT OF SITE INVESTIGATION WORKS

DRG No SCALE DATE BM11216-011 1:2,500 @ A3 SEPTEMBER 2017

DRAWN BY CHECKED BY APPROVED BY JP SJB SDB

SA3 SA4

0 100 200

Reproduced from Ordnance Survey Maps Metres © Crown Copyright All Rights Reserved Wardell Armstrong Licence No. AL100018275 GALLAGHER ESTATES LIMITED PROPOSED HOUSING DEVELOPMENT AT WILDING ROAD, WALLINGFORD GEOLOGICAL REPORT IN SUPPORT OF MWLP PART 2 CONSULTATION RESPONSE

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BM11216 SEPTEMBER 2018

5.3

Air Quality - Qualitative Assessment

Update

CLIENT: Mr Aritz Kaushik, L&Q Estates Limited

PROJECT: Land North of Wilding Road, Wallingford

SUBJECT: Air Quality - Qualitative Assessment Update

JOB NO.: BM11216

DATE: 30th July 2020

PREPARED BY: Emily Forster/Mariam Weatherley

Introduction

Wardell Armstrong (WA) LLP has been commissioned by L&Q Estates Limited to review the current air quality situation in Wallingford, in relation to a proposed development situated to the north of Wilding Road and to the east of Wantage Road, Wallingford. The proposed development comprises up to 365 residential dwellings, a 1 form entry primary school and associated accesses, open space and landscaping. This note has been prepared to accompany representations to be made to the Wallingford Neighbourhood Plan (Regulation 15) consultation and to inform L&Q Estates’ participation in examination of the South Oxfordshire District Council Local Plan.

The proposed development is located within the administrative area of South Oxfordshire District Council (SODC), which is responsible for the management of air quality in the vicinity of the proposed development site. There are currently three AQMAs in the area administered by SODC, in Henley, Watlington and Wallingford. The nearest Air Quality Management Area (AQMA) to the proposed development site is the Wallingford AQMA, which had been

BM11216/001 Page 1 JULY 2020

Air Quality - Qualitative Assessment

Update

declared as an AQMA for exceedances of annual average NO2, approximately 800m south of the site boundary.

Previous air quality assessment work for this proposed development has been undertaken by WA in 2017, to assess whether the site is suitable for development. The assessment concluded that there were no significant air quality impacts as a result of the development. This report reviews the air quality concentrations at the time of the 2017 air quality assessment and the current air quality concentrations in the area, taking into account the air quality monitoring data in the Wallingford AQMA and changes to background concentrations as well as recent updates to guidance.

Previous Assessment

To assess the impact of the proposed development in relation to air quality, the air dispersion model ADMS-Roads was used to assess the impact of development generated traffic on local air quality at seven existing receptors. The air quality concentrations at these seven receptors were previously assessed for the base year, 2015, and for the opening year of 2024. Of the seven receptors, four were selected within the Wallingford AQMA. This assessment used 2015 background concentrations derived from 2013-based Defra background maps. The 3 results of the assessment indicated a maximum increase of NO2 of only 1.22ug/m at a receptor situated within the AQMA with a concentration comfortably below the Air Quality Objective. The proposed development was concluded to have a ‘not significant’ effect on human health.

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Air Quality - Qualitative Assessment

Update

Changes in Air Quality Assessment Since 2017

Local Air Quality

The 2019 Air Quality Annual Status Report (ASR), the most recent air quality report available from SODC, summarises the monitoring data for the previous year of 2018. SODC operates a network of 62 non-automatic monitoring locations (NO2 diffusion tubes); five of which are located in the Wallingford AQMA, as detailed in the graph provided, which provides annual average NO2 concentrations between the years 2014 and 2018.

The graph indicates that between 2014 and 2018, the overall trend of NO2 has decreased at each monitoring location situated in the AQMA. Diffusion tube, reference S19-21, CA is the only monitoring location within the AQMA which has recorded an exceedance of the NO2 3 annual average objective of 40µg/m . For the most recent year of 2018, the recorded NO2

BM11216/001 Page 3 JULY 2020

Air Quality - Qualitative Assessment

Update concentration at this same monitoring location, was 37.4µg/m3, which is just below the air quality objective. By 2018, all monitoring locations within the Wallingford AQMA are below the objective level for NO2.

Background Concentrations

Background concentrations in the absence of measurement from background sites are derived from the default concentration maps as provided by Defra. In the 2017 assessment, the Defra 2013 background maps were used to derive background concentrations. Since the original assessment, there have been two updates to the background maps, where 2017 is the most recent and which is currently used for air quality assessments. The difference in background pollutant concentrations in Wallingford between the previous assessment (which utilised a 2015 base year) and currently (which would use 2019 as a base year) is presented in Table 1 below.

Table 1: Change in Background Concentrations since the previous assessm ent 2015 Pollutant 2019 Pollutant Concentrations Concentrations (µg/m 3) – (µg/m3) – utilising Defra 2017 Pollutant utilising Defra 2013 Background Maps (to be used Background Maps for the updated assessment)

Oxides of Nitrogen (NO x) 19.91 18.45

Nitrogen Dioxide (NO2) 14.07 13.15

Particulate Matter (PM10) 15.20 13.90

Particulate Matter (PM2.5) 10.87 9.73

Table 1 shows that the previous assessment background concentrations have decreased in the Wallingford area for all pollutants of concern. If the air quality assessment were to be

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Air Quality - Qualitative Assessment

Update updated through dispersion modelling, this would take into account lower background concentrations, and potentially result in lower air quality pollutant concentrations at the same sensitive receptors previously assessed, including those situated in the Wallingford AQMA.

Vehicle Emission Factors

Air quality assessments use vehicle emissions factors are calculated using the Emissions Factor Toolkit (EFT), to predict road vehicle pollutant emission rates based on a certain year, road type, vehicle speed and vehicle fleet composition. The previous 2017 assessment which used an older version of the EFT, provided a highly conservative approach, on the assumption that there would be no improvement in vehicle emissions over time and it is therefore likely that impacts presented in the chapter have been over predicted. An updated assessment would utilise current EFT v9.0, (incorporating forecasted improvements in air quality) and it is therefore considered that the results would be a more realistic assessment of future conditions with conclusions remaining the same as for the 2017 assessment whereby impacts were predicted to be ‘not significant’, including within the Wallingford AQMA.

Updated Assessment

An updated assessment of sensitive receptors within the Wallingford AQMA will be undertaken to consider the updates in local air quality in Wallingford, new background concentrations and improved vehicle emission factors. As air quality has improved since the previous assessment, and future air quality concentrations are predicted to improve, it is anticipated that the predicted impact of the proposed development on existing receptors could be lower than those presented in the previous 2017 assessment. This will be confirmed within a subsequent technical air quality assessment, through undertaking an updated detailed air quality assessment, to support this expectation.

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Air Quality - Qualitative Assessment

Update

Summary

Since the original assessment for the proposed development in Wallingford, completed in

2017, local air quality concentrations have improved, in particular NO2 concentrations within the Wallingford AQMA, which are now below the 40µg/m3 objective level. Updates to background concentration maps and the EFT reflect the improvements in air quality and improved vehicle fleet. The updated assessment, which is due to be completed by mid- September will take into account these improvements in air quality and in the way it is assessed, to provide a more accurate potential impact of the proposed development on existing receptors in the Wallingford area, including those situated in the Wallingford AQMA.

BM11216/001 Page 6 JULY 2020

Title Mr

Name Michael Knott

Job title (if relevant) Director

Organisation (if relevant) Barton Willmore

Organisation representing (if relevant) L&Q Estates

Address line 1 The Blade

Address line 2 Abbey Square

Address line 3

Postal town Reading

Postcode RG1 3BE

Telephone number 01189430000

Email address [email protected] Response 10

Respondent Details

Information

Respondent Number: 10 Respondent ID: 146413823 Date Started: 12/08/2020 11:19:48 Date Ended: 12/08/2020 11:31:58 Time Taken: 12 minutes 9 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from Chilterns Conservation Board.

Q3. You can upload supporting evidence here.

File: Chilterns Conservation Board 07.08.2020.pdf

Your details and future contact preferences

Contact: Michael Stubbs Chairman: Cllr Ian Reay Tel: 01844 355507 Vice Chairman: Ray Payne Fax: 01844 355501 Chief Officer: Dr Elaine King E Mail: [email protected] www.chilternsaonb.org

5th August 2020

By email only to [email protected] My Ref.: F:\Planning\Planning Policy\Wallingford Neighbourhood Plan

Wallingford Neighbourhood Plan – Regulation 14 Consultation (16th June to 11th August)

Dear SODC Neighbourhood Planning

The Chilterns Conservation Board (CCB) is grateful for the opportunity to submit comments on the Regulation 14 Pre-Submission Consultation Draft of the Wallingford Neighbourhood Plan.

CCB commends the vision and spatial strategy in the plan and the comprehensive evidence base as advanced.

To assist, we set out the duties and responsibilities of the CCB in Annex 1, at the end of these representations. For ease of reference we have tabulated our points, with additional text as underlined or deleted text as ‘strikeout’ text. All bold text denotes existing policy or supporting content in the pre-submission Neighbourhood Plan.

Wallingford Neighbourhood Parish Neighbourhood CCB points in support and justification of these Plan, with proposed CCB additions/deletions. amendments and/or additional details. Foreword We support and commend this foreword, which deals with the contextual relationship of Wallingford to its landscape and riparian setting, to which the Chilterns AONB is one of three principal components (the others being the North Wessex Downs and the River Thames). 2.1 Vision and Objectives We support this.

2.1.2 Wallingford will accommodate the level The ‘attractive landscape setting’ could justifiably of growth required to meet our local housing need whilst conserving and enhancing the be raised to ‘attractive highly valued landscape heritage assets of this market town described setting’. in Chapter 4 and its attractive landscape setting. As part of this the Plan promotes 1

sensitive development of high-quality This reflects the AONB’s nationally protected sustainable design and design standards that landscape status of the land that surrounds. retain and enhance the local character of the The Landscape Institutes GLVIA 3rd edition town and promote contemporary design where it makes a positive contribution to the professional guidance provides the background townscape. rationale to support a highly valued landscape. 2.2 Planning Policy Framework We support this.

2.4.25 In order to support the development of Site E when combined with the redevelopment of Site E and influence the development of the the CABI site will impact on the wider landscape site in a positive way, to maximise linkages to context of the town, for example when viewed the Town Centre and services, whilst minimising the impact of the development on from The Ridgeway National Trail to the east of the setting of the town and fully supporting the Mongewell, on the rising topography as you walk Green Network, the Steering Group eastwards. commissioned its own Landscape Assessment. Applicants will be expected to demonstrate Any detailed planning application in the future must that detailed plans for Site E are in general be supported by an appropriate landscape accordance with the principles outlined in this assessment, so that the form and configuration of document. development maintains an appropriately open aspect and settings relationship to the wider landscape, including the AONB landscape.

2.4.26 Wallingford is well screened and We support this. unobtrusive in the wider landscape, particularly from prominent viewpoints, this is largely a As above, the use of an appropriate landscape and result of the well wooded nature of the town. visual impact assessment is necessary to protect We believe that in view of the town’s rural the setting of the town and conserve and enhance location, proximity to two AONBs, important heritage assets and the location of the new the setting of the AONB. strategic housing sites on the periphery of the town that it is important there continues to be space for substantial trees and other landscaping to soften the appearance of new development. We therefore propose that new development on large sites should be at a moderate density and that densities on small sites should have particular regard to local character and circumstances.

Chapter 5 Natural Environment We support these policies. 5.1 Vision and Objectives Policy ENV 02 also falls within the AONB ENV 02: Secure measurable net biodiversity gains as recommended by Natural England. Management Plan’s General Policy 4 objectives Ensure all new development integrates and (page 27 of the 2019-2024 Management Plan), delivers net gains for biodiversity within plans, to use the natural capital provided by the and contributes to the restoration and Chilterns more sustainably to enhance the enhancement of the biodiversity of green and AONB and contribute to the delivery of the blue infrastructure, including the River Thames and its tributaries e.g. Bradford’s Brook, and government’s 25 year Environment Plan. the priority habitats of the Thames Wallingford to Goring Conservation Target Area. Further, this also delivers the strategic objectives of the Management Plan (Nature – page 37), including Management Plan policy NO1 to ‘Ensure that spaces for wildlife are

expanded, well connected, well managed and

diverse’. This AONB policy is also consistent with the NPPF 170 (d) regarding net gains and establishing coherent ecological networks. 2

Natural Environment Policies We support this policy.

Policy

EV1.1(d) respect and protect the setting of the Chilterns and North Wessex Downs AONBs, the River Thames and its floodplain to enhance the ecological and natural capital value of the river, its banks, the Thames Path National Trail and use of the river for formal and informal recreation and promote tourism. Appendix B – Site Assessment for Site B We support the landscape evidence base that underpins the implementation of this policy. This links to our previous point with respect to paragraph 2.2 of the Neighbourhood Plan.

Evidence base F2 Chapter 2 – Strategy for The (new) AONB Management Plan is now in Wallingford force and is now the Management Plan for Sections F.2.2 and F5.2. 2019-2024.

The Chilterns AONB is nationally protected as one of the finest areas of countryside in the UK. Public bodies and statutory undertakers have a statutory duty of regard to the purpose of conserving and enhancing the natural beauty of the AONB (Section 85 of CroW Act).

The Chilterns Conservation Board is a body that represents the interests of all those people that live in and enjoy the Chilterns AONB. It is made up of representatives nominated by the organisations listed in Appendix 1.

Should you require any further information please do not hesitate to contact me.

Yours sincerely,

Dr Michael Stubbs MRICS MRTPI Planning Advisor For and on behalf of the Chilterns Conservation Board

Appendix 1: About Us

The Chilterns Area of Outstanding Natural Beauty

The Chilterns AONB was designated in 1965 for the natural beauty of its landscape and its natural and cultural heritage. In particular, it was designated to protect its special qualities which include the steep chalk escarpment with areas of flower-rich downland, woodlands, commons, tranquil valleys, the network of ancient routes, villages with their brick and flint houses, chalk streams and a rich historic environment of hillforts and chalk figures.

Chilterns Conservation Board

The Chilterns Conservation Board is a statutory independent corporate body set up by Parliamentary Order in 2004 under the provisions of Section 86 of the Countryside and Rights of Way (CRoW) Act 2000. The Board has two statutory purposes under section 87 of the CRoW Act: a) To conserve and enhance the natural beauty of the AONB; and b) To increase the understanding and enjoyment by the public of the special qualities of the AONB. In fulfilling these roles, if it appears that there is a conflict between those purposes, Conservation Boards are to attach greater weight to (a). The Board also has a duty to seek to foster the economic and social well-being of local communities within the AONB. Like all public bodies, including ministers of the Crown, local authorities and parish councils, the Chilterns Conservation Board is subject to Section 85 of the CRoW Act which states under “General duty of public bodies etc” “(1) In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.”

List of Organisations providing Nominees to the Chilterns AONB Conservation Board

The Chilterns Conservation Board has 27 board members, all drawn from local communities:  Hertfordshire and Oxfordshire County Councils  Central Bedfordshire and Luton Borough Councils (unitary authorities)  Buckinghamshire Council (formerly Aylesbury Vale, Chiltern and South Buckinghamshire, and Wycombe District Council).  Dacorum Borough Council, North Hertfordshire DC, Three Rivers DC and South Oxfordshire DC.  The Central Bedfordshire, Buckinghamshire, Hertfordshire and Oxfordshire Parish Councils (6 elected in total), and  DEFRA (8 in total).

Title Dr

Name Michael Stubbs

Job title (if relevant) Planning Advisor

Organisation (if relevant) Chilterns Conservation Board

Organisation representing (if relevant)

Address line 1 The Lodge

Address line 2

Address line 3

Postal town

Postcode OX39 4HA

Telephone number 01844 355507

Email address [email protected] Response 11

Respondent Details

Information

Respondent Number: 11 Respondent ID: 146414457 Date Started: 12/08/2020 11:32:04 Date Ended: 12/08/2020 11:37:59 Time Taken: 5 minutes 54 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from Oxfordshire County Council.

Q3. You can upload supporting evidence here.

File: County 07.08.2020.pdf

Your details and future contact preferences

OXFORDSHIRE COUNTY COUNCIL’S RESPONSE TO THE FOLLOWING CONSULTATION: District: South Oxfordshire Consultation: Wallingford Neighbourhood Plan 2019-2034 (Reg 15 Consultation)

This report sets out Oxfordshire County Council’s view on the Wallingford Neighbourhood Plan 2019-2034 Reg 15 Consultation

Annexes to the report contain officer advice.

The County Council continues to support in principle the ambition of Wallingford Town Council to adopt a Neighbourhood Plan.

Oxfordshire County Council provided comments in October 2019 on the Draft Pre- Submission Plan and we welcome the amendments made in response to our comments. However, we consider that further changes are necessary to meet the Basic Conditions as per the detailed officer comments found in Annex 1.

The County Council is not requesting a hearing and would only seek to attend a hearing if the Examiner considers it would be useful.

Officer’s Name: Lynette Hughes Officer’s Title: Senior Planner Date: 07 August 2020

ANNEX 1

OFFICER ADVICE

Team: Strategic Planning Officer’s Name: Lynette Hughes Officer’s Title: Senior Planner

Strategic Comments

The Wallingford neighbourhood plan will be one of the more significant neighbourhood plans in South Oxfordshire District, covering the area of a market town. Wallingford has seen considerable growth in recent times, and this growth is set to continue with allocations and consents yet to build out including: • 555 houses on the Core Strategy allocated site Wallingford Site B (Slade End). Outline consent was granted in October 2017 to P14/S2860/O and there have been Reserved Matters applications since. • 85 houses at Winterbrook. Full consent was granted on appeal in March 2016 to P15/S0191/FUL and the site is building out. • 502 houses at Wallingford Site E. Outline consent was granted in August 2019 to P16/S4275/O and Reserved Matters applications are expected soon.

This Plan proposes to allocate Wallingford Site E (Policy WS2) reflecting the outline consent noted above. We consider that it is appropriate to allocate the land as proposed.

An employment site at Wallingford Site C west of Hithercroft Industrial Estate is to be allocated in Policy EE1 – 3.1ha. This policy provides the additional land needed in Wallingford for employment uses as identified in the emerging Local Plan policy EMP1. We consider that this appears to be reasonable and consistent with a strategic approach to development in the town. Site C has had the benefit of planning permission P14/S2633/FUL in the past and is currently the subject of P20/S1179/FUL.

The reasons for not allocating ‘Site A’ are set out on page 138-139 of the neighbourhood plan. We support those reasons. We are also supportive of the reasons for not allocating ‘Site D’ set out in the draft neighbourhood plan insofar as they are consistent with our objection to the mixed-use development of that site in P18/S2506/O which was refused in January 2020 and is currently the subject of an appeal. We note that site promoters for Sites A and D: Barton Willmore for L&Q Estates; Optimis for Croudace and Turley for David Wilson Homes were represented at Local Plan hearings this month.

The County Council is currently considering the pre-submission draft of the adjoining Crowmarsh Gifford neighbourhood plan, comments for which close on 21st August 2020.

Team: South & Vale Locality Officer’s Name: Rebecca Crowe Officer’s Title: Transport Planner

Transport Comments

Objective MC06, on page 105 ‘Ensure that new development contributes positively to transport and movement within Wallingford. All new and extended homes should have adequate onsite parking and should not rely on street parking to meet their needs’. and Policy MC5.1 on page 110 ‘New housing proposals should meet the requirements in Oxfordshire County Council’s Residential Parking Provision Policy, other than for new residential developments, including extensions to existing homes, where parking must be provided in accordance with the following minimum standards’

OCC Comment:

Our suggested amendment to the objective at the draft plan stage was not made. Oxfordshire County Council’s parking standards do allow for some on street parking, and a reasonable case may be made by developers to provide on street parking. It is accepted that the objective may allow for this.

Our suggested amendment to the policy was not made. The policy as it stands is unclear and contradictory. It states that new housing proposals should meet the County Council’s parking standards, but immediately follows that with an exception for new residential developments. Therefore, we suggest that the policy MC5.1 wording is replaced with the following: ‘Development proposals should meet Oxfordshire County Council’s minimum parking standards. Where feasible and appropriate, they should also meet the following standards.’

Policy MC6.1, on page 111 ‘Land immediately to the west of the existing railway line, 10m in width, as shown on the Proposals Map shall be protected from built development. This strip shall be used to enable the provision of commuter train services from Wallingford Station, and to provide an enhanced walking and cycling route. No development should take place in this corridor which would preclude its use for transport and movement.’

OCC Comment:

The policy has been updated from the draft plan. We support the principle of the potential of this route as a pedestrian and cycle route which may also require safe crossings of the railway line.

Paragraph 10.1.11, on page 133 ‘The Town Council will work with Oxfordshire County Council and other partners towards (i) designating Wallingford a 20mph zone (ii) designating Wallingford a ‘No Entry’ except for access area thereby prohibiting non-emergency through traffic, and (iii) exploring the use of technology to police (i) and (ii).’

OCC Comment:

We note that clarification has been provided for point ii further to our comments on the draft plan. There are significant technical challenges in enforcing access restrictions that apply to larger areas such as a town. Although in principle this is not something OCC has a significant issue with, restricting access to through traffic is highly unlikely to be enforceable. We therefore raise concern with this option as it is difficult to deliver and likely to be very costly. OCC does not have funding for these types of measures.

Policy MC2.4, on page 108 ‘Development proposals should contribute to the provision and improvement of bus transport infrastructure within the town centre.’

OCC Comment:

This is an additional policy to that contained in the draft plan and we are supportive of it in principle. We suggest that contributions sought for bus infrastructure should not be limited to within the town centre. Additionally, these should not only be limited to infrastructure but should also include service improvements. Therefore, we suggest the following amendments to the policy: ‘Development proposals should contribute to the provision and improvement of bus transport infrastructure related to the site and services connecting Wallingford with other locations within the town centre.

Team: Strategic Infrastructure Officer’s Name: David Early Officer’s Title: Transport Planner

Strategic Walking and Cycling Comments

Page 20 states that: “it will be supported by appropriate parking, transport and links for walking and cycling”.

Walking and cycling are two very different modes. No mention is made of walking facilities such as crossing points, direct routes to shops, public transport and green space.

Paragraph 2.3.5: This paragraph should be specific on walking infrastructure. This should include comfortable footways, safe crossing points where needed, regular maintenance of footways and signage to shops and public transport.

The Neighbourhood Plan should ensure that walking facilities are prioritised. Walking is free and inclusive. Ideally, facilities should include benches and removal of redundant furniture. Widths of footways should be generous, given concerns about social distancing. Walking is at the top of the hierarchy of modes but is often neglected when implementation is involved.

Team: Education Officer’s Name: Barbara Chillman Officer’s Title: Pupil Place Planning Manager

Education Comments

Paragraph 9.2.27 states that ‘Wallingford has two primary schools and a junior school: Fir Tree Junior School, St John Primary School and St Nicholas CoE Infants.’ As a matter of accuracy, this should say “one primary school, one infant school and one junior school”. St John’s is a full primary school, offering provision from Reception to Year 6, while St Nicholas offers places from Reception to Year 2 (as well as a nursery class), and Fir Tree offers places from Year 3 to Year 6. However, in the longer term it is proposed that both St Nicholas and Fir Tree will become primary schools, providing places from Reception to Year 6, which would facilitate expansion of primary education capacity within Wallingford by up to 2 forms of entry. This would involve the relocation of St Nicholas to within the strategic housing development at Slade End ‘Site B’. In the interim, temporary accommodation has been installed at St Nicholas to allow the school to increase its admission number.

Given that Site B is progressing, it will not be necessary to have a primary school on Site E.

Paragraph 9.2.29 states that Wallingford School is ‘operating at its capacity of an intake of 190 pupils per year and is heavily over-subscribed with a waiting list.’ To ensure children are able to attend their local school, Wallingford School is in the process of expanding. Since 2019 its admission number has been 216 and, subject to the completion of additional permanent accommodation, the school’s admission number will increase again to 242, and total capacity to around 1,500.

Team: Oxfordshire County Council Estates Officer’s Name: Karen Lister Officer’s Title: Head of Estates and Strategy

Estates Comments

Oxfordshire County Council (OCC) Estates welcomes the opportunity to comment on the Wallingford Neighbourhood Plan.

Following comments made on the previous draft document regarding OCC sites, it is important to note an update regarding a change to paragraph 7.7.4 from the previous draft. The amendment states: “Land at St Georges Road which has been used until recently as playing fields is being considered for car parking use in order to enable the school to expand on its current site”. This amendment was made after the application had been referred to the Secretary of State, however in a letter dated 25 February 2020, the Secretary of State communicated that they had decided not to call in this application and was content that it should be determined by the LPA. The application was subsequently approved on March 04th 2020, and the wording of 7.7.4 should be amended as such.

Since the previous consultation there has also been an approval for a linked application for the extension of Wallingford School (P19/S0191/FUL), once more this should inform an amendment to paragraph 7.7.4.

Team: Waste Management Officer’s Name: Mark Watson Officer’s Title: Waste Strategy Projects Officer

Waste Management Comments

Oxfordshire councils have ambitious targets to reduce the amount of waste generated and increase the amount recycled as demonstrated in our Joint Municipal Waste Management Strategy 2018-2023.

Chapter 9 of the Neighbourhood Plan sets out the importance of developing protecting and developing community facilities. We made comments on the draft neighbourhood plan in October 2019. Given the pressing urgency of climate change and the need to embed the principles of the circular economy into all areas of our society, we would encourage the team to state their support for community spaces that help reduce waste and build community cohesion through assets such as community fridges, space for the sharing economy (library of things), refill stations, space for local food growing etc. in the plan.

Team: Mineral and Waste Planning Policy Team Officer’s Name: Anna Herriman Officer’s Title: Mineral and Waste Planning Policy Officer

Minerals and Waste Comments

Our comments remain the same as those dated 8th October 2019 for the previous draft neighbourhood plan consultation. The comments were as follows:

The area covered by the neighbourhood plan is in Strategic Resource Area 5 (Thames and Lower Thame Valleys - Oxford to Cholsey (Sharp sand and gravel) (Policies M3 and M8 of the Oxfordshire Minerals and Waste Local Plan: Part 1 – Core Strategy) and part of the neighbourhood plan is in a Minerals safeguarding area and consultation area under policy M8. We support the neighbourhood plan not allocating land for housing in these areas.

There are also two known Mineral sites adjoining the area of the neighbourhood plan. New Barn Farm is the existing permission (MW.0094/16), and White Cross Farm (Wallingford Marina) MW0033/18 is a current application undergoing determination. White Cross Farm is also a nominated site (SG60). Even though both sites are adjoining, they are outside the Neighbourhood Plan area so therefore we don’t have any comments.

Title

Name Lynette Hughes

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Address line 1 County Hall

Address line 2 New Road

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Postal town Oxford

Postcode OX1 1ND

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Email address [email protected] Response 12

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Respondent Number: 12 Respondent ID: 146415480 Date Started: 12/08/2020 11:38:04 Date Ended: 12/08/2020 12:02:21 Time Taken: 24 minutes 16 seconds Translation: English IP Address: Country: United Kingdom

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Response received below via email from Turley on behalf of David Wilson Homes.

Q3. You can upload supporting evidence here.

File: David Wilson Homes (Southerm) 11.08.2020.pdf

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Wallingford Neighbourhood Plan

Representation on behalf of David Wilson Homes (Southern)

Land at Hithercroft Farm, Wallingford

August 2020

Contents

1. Introduction 3

2. Response to Draft Policies 4 3. Conformity with Basic Conditions 12

4. Conclusion 16

David Murray-Cox Taylor Cherrett [email protected] [email protected] Client David Wilson Homes (Southern) Our reference DAVR3006

11th August 2020

1. Introduction

1.1 These representations have been prepared on behalf of our clients, David Wilson Homes (Southern) (herein referred to as “DWS”) in respect of the Wallingford Neighbourhood Plan Group proposed submission draft Neighbourhood Plan Regulation 16 consultation (herein referred to as the “Neighbourhood Plan” or “Plan”), which is currently out at consultation running until 11th August 2020.

1.2 Our client has an active interest in land at Hithercroft Farm, Wallingford (Site D as identified within the Plan) for a development comprising of up to 170 dwellings and 3.1ha of employment floorspace including land for a nursery (Application Reference: P/18/S2506/O / Appeal Reference APP/Q3115/W/20/3254247).

1.3 DWS considers that there are no technical or planning reasons why this site could not accommodate a development of the form proposed by the current proposals. Wallingford is a highly sustainable location within the District and we consider that this should be reflected in the planning policy context for the area.

1.4 Furthermore, DWS consider that the land at Hithercroft Farm is the only realistic option available for the ongoing and future growth of Wallingford given the constraints present elsewhere around the town.

1.5 These representations examine relevant policies, appendices and evidence base documents forming part of the Submission Draft Neighbourhood Plan, highlighting issues to be addressed, and inconsistencies with National and Local Planning Policy, including emerging proposals of South Oxfordshire District Council. It builds on previous representations submitted by DWS to past consultations on the emerging Neighbourhood Plan.

1.6 To confirm, our clients would like to participate in the examination of the Neighbourhood Plan. Please accept this as our registration to do so.

2. Response to Draft Policies

2.1 DWS do not consider that the draft Neighbourhood Plan (“the draft NP”) meets the “basic conditions” (see paragraph 8(2) of Schedule 4B to the TCPA 1990).

2.2 In this section, we comment specifically on the policies within emerging Neighbourhood Plan, including, where applicable, the evidence base documents and appendices.

Policy WS1: The Local Strategy for Wallingford

2.3 DWS are concerned that this policy is overly restrictive and is not positively prepared as required by the National Planning Policy Framework 2019 (The ‘Framework’).

2.4 Point WS1.1 (a) of the policy notes that “(a) support a locally appropriate level of housing growth in the town, to create a compact form and to use land efficiently, whilst also restricting inappropriate development in the countryside areas outside the town”.

2.5 DWS would strongly suggest that this policy is amended, with the wording – “whilst also restricting inappropriate development in the countryside areas outside the town” removed.

2.6 The Town Council will be aware that South Oxfordshire District Council (SODC) has been preparing a new Local Plan to cover the period to 2034 and a draft of that Plan has been submitted for Examination and the subject of hearing sessions. That draft Plan has been prepared in the context of the Oxfordshire Housing & Growth Deal and the requirements / commitments that it expects of the Oxfordshire local planning authorities.

2.7 However the Town Council will also be aware that there is a significant degree of objection to that emerging Local Plan, including to the approach that SODC has applied to identifying, distributing and allocating sites for development. Those concerns have been expressed by parties across the spectrum including residents, local interest groups and the development industry (including by DWS) throughout the examination process. Key to those concerns expressed by many respondents to the Local Plan have been the extent to which SODC relies upon sites currently in the Green Belt and sites where their deliverability/sustainability is highly questionable (for example Chalgrove Airfield).

2.8 The new Local Plan for the District is being examined against the policies in the Framework 2019. The implication of this is that exceptional circumstances could only be demonstrated to justify the release of land from the Green Belt where all other reasonable options for meeting the identified needs for development have been fully examined. In addition, the Framework places a greater onus on the need to ensure that Local Plan allocations are deliverable. DWS consider that the Green Belt sites selected for allocation in the current version of the draft Local Plan are not justified by a full examination of the alternative options available and that the available evidence does not demonstrate that a number of proposed allocations are deliverable during the Plan period.

2.9 As a consequence, DWS consider that there is a very real prospect that amendments to the emerging Local Plan will be required in order to ensure that it is found sound. As one of the most sustainable settlements in the District, there is a significant prospect that any such review could direct additional development to Wallingford.

2.10 Notwithstanding the abovementioned concerns, it is clear that the draft Plan has been prepared following and in response to the emerging Local Plan. If the Town Council wishes to ensure that it has an enduring Neighbourhood Plan which reflects the planning policy context in the District, it would be reasonable to delay its publication until that wider strategy is known or at the very least ensures that the proposed policies are sufficiently flexible as to allow development to come forward.

2.11 DWS considers that it is fundamental that any Neighbourhood Plan produced for Wallingford at this stage does not predetermine any decisions which may subsequently be taken in relation to the wider planning of the area.

2.12 In this context Policy WS1 is overly restricted and should be modified to positively plan for the growth of Wallingford.

Policy WS2: The Land Allocation for Housing in Wallingford

2.13 Policy WS2 seeks to allocate land at west of Reading Road, south of Bradford’s Brook, north of the Wallingford bypass (A4130) for up to 502 new homes.

2.14 DWS do not consider it is necessary for the site to be identified as an allocation. It already exists as a commitment by virtue of the fact planning permission has been granted under reference P16/S4275/O).

2.15 The Plan at paragraph 2.4.20 indicates that the purpose of the allocation is to “secure the delivery of an appropriate level of growth and to guide decisions on any reserved matters applications or revised schemes.”

2.16 These matters can be secured through appropriately worded Development Management policies and will also be controlled through the parameters of the outline planning consent. A specific allocation policy is not therefore necessary.

2.17 Rather, it is DWS’s view that the purpose of this allocation is solely to allow the Neighbourhood Plan area to benefit from a three year housing requirement by virtue of having an adopted Neighbourhood Plan in place which makes housing allocations. The fact of the matter is that the Council have not sought to allocate any additional land, over and above that already committed.

2.18 DWS would request that the policy is removed.

Policy HD1: Design

2.19 DWS note that no changes have been made to this policy following our previous representations.

2.20 DWS raise significant concerns regarding Policy HD1.3 which requires development to “be in accordance with the process and principles of the South Oxfordshire Design Guide, the Outer Wallingford Area Character Assessment, the Wallingford Conservation Area Appraisal and the Winterbrook Character Assessment.”

2.21 The documents referred to in Policy HD1.3 are not Local Plan Documents and have not been subject to examination, and in some cases, not been consulted upon. However, the effect of HD1.3 is to elevate the status of these documents to Development Plan policies.

2.22 Furthermore, there is no assessment as to the impact of the policy on the viability of development. This is not a sound basis upon which to prepare and assess the viability of the Plan, especially when one consider the importance the Framework places on the viability of sites at plan-making stage (paragraph 57).

Policy HA3: Views and Vistas

2.23 This Policy refers to views and vistas as defined in a separate document (Map 12 of the Wallingford Conservation Area Appraisal, April 2018).

2.24 We consider that if the Neighbourhood Plan is to establish policies in relation to such views and vistas then they should be identified on material within or appended to the Neighbourhood Plan.

Policy EE1: Allocation of Employment Land at Site C

2.25 Site C is expected to provide all of the additional employment land (other than minor interventions within the existing Hithercroft Industrial Estate).

2.26 DWS is concerned that this reliance is on the basis that Site C has planning permission for existing employment floorspace. However we understand that this permission seeks to address the needs of a specific occupier and so does not allow for any flexibility or further scope for the expansion of the employment floorspace available at Wallingford.

2.27 The live planning appeal for Site D (Ref No: APP/Q3115/W/20/3254247), includes an Employment Land Statement which establishes that the site is considered to be suitable for a mix of uses that reflect the character of the neighbouring Hithercroft Industrial Estate. In response to market signals and economic policy objectives, the mix of uses will comprise the following:

 B1 Business – in particular B1c light industrial use to respond to a perceived gap in the local market.  B8 warehouse and storage – in particular smaller scale warehouses with trade counters, reflecting the comparatively high representation of wholesale sector businesses and employment within Wallingford.

2.28 In addition, the Employment Land Statement explains that:

 The site offers the potential to make a valuable contribution to the Wallingford’s employment land supply and land being sought by Wallingford Town Council through the Neighbourhood Plan process in response to the emerging Local Plan requirement and other important policy objectives.  The provision of additional employment land has the potential to enhance the town’s economic infrastructure, support job creation and maintain its roles as an important employment centre within the district. Alongside providing the overall quantum of employment land identified as being needed in the district, the site also provides potential to respond to the acknowledged demand pressures from SMEs already located in Wallingford that have aspirations to grow. This, in turn, will support the economic aspirations and objectives for new job creation and business growth established in the emerging Local Plan.  The land at Hithercroft Farm, Wallingford, evidently represents a significant opportunity to accommodate development in a strategically significant part of the District - building on existing economic assets – in an area that has already been identified as a focus for housing and employment growth within the emerging Local Plan. The provision of new jobs alongside housing may help to encourage the retention of more skilled residents in the local workforce in response to policy objectives.  The proposed development complements the planned investment in the economic infrastructure across the wider economic geographies within which Wallingford is located. The OXLEP SEP seeks to ensure that appropriate business premises are available in order to support sustainable commercial and community growth. Market towns outside of the knowledge spine are recognised as having the potential to implement the SEP’s policies and make strong contributions to the county’s overall economic growth. This, coupled with national and sub-regional economic strategy which is committed to supporting further economic growth in strongly performing areas, forms a critical strategic context when considering DWS’s proposals that will provide critical infrastructure (both housing and business premises) to support the level of growth envisaged.

2.29 DWS would request that additional employment sites are allocated, such as the 3.1ha at Hithercroft Farm, to diversify the existing commercial stock and support the economic growth of Oxfordshire.

Policy MC6: Cholsey and Wallingford Railway Corridor

2.30 DWS note that this policy seeks to safeguard a strip of land parallel to the west of the railway line, as a sustainable transport corridor for use by pedestrians and cyclists and establishes that no development should take place in this corridor which would preclude its use for transport and movement.

2.31 The land promoted by DWS is located entirely to the west of this railway line and could play an essential role in ensuring that this pedestrian and cycle link could be provided.

2.32 DWS are willing to engage with the Neighbourhood Plan Group to discuss how the proposed corridor can be delivered.

Appendix A – Site Allocations

2.33 Appendix A sets out those sites which are to be allocated for development and those which have been discounted.

2.34 Site D, the land at Hithercorft Farm is discounted as the following circumstances are said to apply:

 This site is not allocated for housing in the SODC Development Plan (Core Strategy and SODC Emerging Local Plan 2034).  Proximity of this site to land used for industrial purposes which would create noise and disturbance for residents.  There is no connectivity with the town centre’s facilities and services.

2.35 In response to these points, we note that:

Bullet Point 1 2.36 The Core Strategy is substantially out of date. Sites were allocated in that document in 2012 to meet the needs of the area as established at that time. Furthermore, the Core Strategy plays no role in meeting needs over the plan period of the WNP. As set out above, there is significant uncertainty over the content of the emerging Local Plan. Furthermore, there is nothing to prevent the Neighbourhood Plan taking the proactive decision to allocate the site for development.

Bullet Point 2 2.37 The planning application was supported by a Noise Impact Assessment and Air Quality Assessment prepared by competent professionals, neither of which has indicated that the site would be subject to noise and disturbance from the nearby Hithercroft Industrial Estate, or the employment activities proposed on the site itself. Furthermore, SODC’s Environmental Health Officer has raised no concerns in this regard from the proposed development. It is therefore not a sound reason to discount the site.

Bullet Point 3 2.38 DWS do not agree that there is no connectivity between the site and the town centre. The nearest bus stops are approximately 700m from the site access point. The development proposals provided for new bus stops in either direction on Hithercroft Road. These new facilities will be within 600m from the site access, and would be accessible via the direct footway and cycle path proposed as part of the development. In addition, Wallingford town centre is comfortably within a 30-minute walk of the site and indeed the main shopping area is a shorter walk (less than 20 minutes) of the development site which is the location of the main local amenities serving the site.

2.39 Further context is provided by the CALA Homes appeal site known as Carmel Meadows (considered under PINS ref: APP/Q3115/W/16/3165351). In that case, the development proposed “the demolition of existing buildings and erection of a new headquarters for CABI; erection of 91 dwellings, comprising open market and

affordable housing, provision of open space, landscaping and parking and other associated works.”

2.40 In the CALA appeal, the Inspector addressed the matters of modal shift and accessibility and found:

“54. The appeal site is outside the town of Wallingford and the village of Crowmarsh Gifford. However, it is relatively close to both settlements and I would not judge it to be remote. New residents could reasonably look to the former for most of their day-to-day shopping needs and to access local services. Crowmarsh Gifford has a few facilities, including a primary school and nursery.

55. It is possible to walk to Wallingford from the site either along the roads or across the fields along the bridleway or footpaths. The road route via Nosworthy Road and Reading Road is not a particularly pleasant walk, in my opinion. The first part of the route is unlit, the footways are narrow in places and along Reading Road the pedestrian has to cross from one side to the other several times. The journey took me about half an hour from the Market Place and is about 2.3 km. The alternative field route is a more pleasant walk although the bridleway becomes quite narrow as it strikes north from the hard surfaced section. The distance and time taken is roughly similar. In my opinion those with pushchairs, mobility issues or heavy shopping to carry would be very unlikely to choose to walk into Wallingford by either route. The primary school is perhaps an easier walk as it is along the surfaced bridleway and Old Reading Road. It is though also about a half hour walk and so for many the temptation would be to undertake it by car, especially in inclement weather or in the winter months.

56. Cycling would be a more attractive option for these journeys, whether they take place along the roads or the bridleways. Howbery Business Park with its employment opportunities is also less than 5 km away along relatively flat terrain. Many residential parts of Wallingford and the surrounding villages are within reasonable cycling distance so that cycling would be a realistic modal choice for CABI employees. Cholsey railway station, with its services to London, Reading and Oxford is a cycle ride of about 3.8 km. Alternatively there are bus stops along Reading Road and it is a short trip from here to the station by bus. As already mentioned the proposals would include accessibility improvements for cyclists and pedestrians through the S106 Agreement.

57. There is a half hourly bus service between Oxford and Reading, which stops outside the site and travels through Wallingford. The buses start early and finish late in the evening and so provide a viable alternative for journeys to work, school or the shops. The S106 Agreement would include a contribution towards the improvement in the frequency of services along this route. The objective is to provide three buses per hour, eventually increasing this to four per hour. A contribution would also be made to improve the bus stops to make them more attractive to use. These would include hardstandings, a pedestrian refuge, bus shelters and real time information.

2.41 In light of this, it is DWS firm view that this reason for the site being discounted is completed unjustified and would not stand to scrutiny.

2.42 DWS also note that the Town Council’s assessment of Site D refers to comments made by Oxfordshire County Council regarding highways matters, DWS consider that those

are unfounded and is engaging actively with the Highways Officers in order to address such matters.

Strategic Environmental Assessment

2.43 We note that the SEA considers two key scenarios: a baseline scenario (allocation of Sites E and C); and an alternative scenario based on the baseline plus the allocation of Site D.

2.44 The SEA reaches a number of conclusions which we consider are fundamentally flawed. The SEA appears to have been undertaken in order to support the preferred (baseline approach) rather than assess alternative options on a sound basis.

2.45 For example, the baseline scenario is said to score more preferably against air quality, despite the SEA noting that the Site D application being supported by an air quality assessment which finds: “Overall, it is concluded that there are no air quality constraints to the proposed residential development”. The SEA appears to have assumed that the inclusion of Site D would lead to greater air quality impacts without any further analysis to enable this conclusion to have been reached. h

2.46 The SEA also concludes that the baseline scenario would score more preferably against biodiversity. The SEA records features of biodiversity interest at Site D, however these have all been taken into account in the preparation of the current application which would, in any event, be required to contribute towards biodiversity net gain. Indeed, the planning application at land at Hithercroft Farm included an Ecological Impact Appraisal which has undertaken biodiversity impact calculations and shows an overall net gain in biodiversity. Again no objections have been raised to the planning application on ecological grounds subject to the imposition of planning conditions.

2.47 The SEA concludes that the baseline scenario would be preferable in relation to landscape and historic environment considerations. However these matters appear to have been heavily influenced by the impact on the adjacent heritage railway which is used infrequently and which has informed the Site D design approach. The scoring in this regard appears to have been based on archaeology matters and we note that this matter is capable of being addressed via condition on any planning permission, as confirmed by Oxfordshire County Council in their consultation response to the application. There is no indication that the site could not accommodate development for archaeology reasons.

2.48 The baseline scenario is also said to score more preferably in relation to land, soil and water resources. However we note that the Agricultural Land Classification report submitted with the current Site D application notes that in common with all other agricultural land around the southern edge of Wallingford outside the flood plain, the site is shown on the Provisional Agricultural Land Classification (ALC) map as Grade 2 land, which is very good quality land. Land to the north of the town is shown as excellent quality Grade 1 land. At this strategic scale this indicates that development around the town should therefore be directed to its southern edge. The detailed ALC survey of the site which demonstrates that the land is mostly Subgrade 3a, with an area of Subgrade 3b land, and as such the site is of lower agricultural quality than neighbouring land around the southern edge of Wallingford. We note the SEA also

indicates that Site E (which is proposed for allocation) comprises Grade 2 agricultural land.

2.49 Against the population and community objective the SEA suggests there is little argument for higher growth in respect of meeting housing and employment objectives, as the target figures set by the emerging South Oxfordshire Local Plan (for Wallingford) will be exceeded under the baseline. The SEA indicates that there also a need to consider the possibility that exceeding the SODC growth target may place strain on services and facilities. In our view, the SEA has failed to have regard to any positive implications that could arise from additional development at Site D, including economic benefits and the provision of additional market and affordable housing. Furthermore, we note that the SEA refers to exceeding growth targets, however it is essential to note that this reference is to the requirements of the emerging Local Plan which itself is highly uncertain and based on the selection of sites where their deliverability/suitability is questionable.

2.50 Against the health and wellbeing objective, again the SEA supports the baseline. However, we consider that this conclusion is flawed. The commentary suggests that the relationship between Site D and Hithercroft Industrial Estate could lead to ‘bad neighbour’ concerns. There is no explanation as to why such issues would arise and such a conclusion is not be supported by the Site D application material or the consultee responses on the application.

2.51 In relation to transport, the SEA refers to comments made by the County Council on the Site D application, however as we establish elsewhere, those comments are unfounded. However, the SEA does in fact acknowledge the sense in locating housing development in this area by stating that “It is fair to assume that any scheme would be mixed use, and there would be good opportunities for residents to walk/cycle to existing employment areas.”

2.52 In summary, the SEA is based on an approach which appears to be designed to support the preferred approach and which has not been based on a reasonable and realistic analysis of the circumstances of each option.

3. Conformity with Basic Conditions

3.1 Having set out the above specific policy objections, we therefore assess the Plan against the “basic conditions” (see paragraph 8(2) of Schedule 4B to the TCPA 1990).

8(2)(a) Having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the neighbourhood plan

3.2 A draft Neighbourhood Plan only meets the basic conditions if, inter alia, “having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the order”: paragraph 8(2)(a) of Schedule 4B TCPA 1990.

3.3 In order to have regard to a policy as a matter of law, that policy has to be interpreted properly by the decision maker. A decision maker who misinterprets policy does not have regard to it and errs in law: see EC Gransden v Secretary of State (1987) 54 P. & C.R. 86, as renewed in Tesco Stores Ltd v Dundee City Council [2012] PTSR 983.

3.4 A central flaw in the draft NP is that there is no certainty at this stage that the Plan meets the assessed housing needs arising in the area over the Plan period. This is contrary to the policy approach set out in the NPPF (paragraphs 16, 17(3), 47, 49, 184) and the PPG paragraphs set out above.

3.5 As set out above, the PPG makes clear that where neighbourhood plans contain policies relevant to housing supply these policies should take account of the latest and up-to-date evidence of housing need (para 040 ref id 41-040-20160211).

3.6 There is no documentary evidence that these matters were considered with the Council’s Officers, which is a breach of the guidance on the need for agreement on the relationship between the emerging NP and emerging Local Plan under Paragraph: 009 Reference ID: 41-009-20160211.

3.7 Further the PPG states:

“The resulting draft neighbourhood plan must meet the basic conditions if it is to proceed. National planning policy states that it should support the strategic development needs set out in the Local Plan, plan positively to support local development and should not promote less development than set out in the Local Plan or undermine its strategic policies (see paragraph 16 and paragraph 184 of the National Planning Policy Framework).” (Paragraph: 044 Reference ID: 41-044-20160519)

3.8 In other words, both national planning policy and the Secretary of State’s guidance advise that neighbourhood plans have to be consistent with and not in conflict with the provision of housing to meet objectively assessed evidence of need. This is reinforced by PPG Paragraph: 069 Reference ID: 41-069-20140306 which specifies that neighbourhood plans must “not constrain the delivery of important national policy objectives”.

3.9 The starting point for a neighbourhood plan such as that proposed must be the identification of objectively assessed housing needs by the Local Planning Authority, and a detailed documentary trail demonstrating how that has been undertaken by the qualifying body which has the ambition of making provision for housing, and imposing any constraints.

3.10 At this present time in remains uncertain as to the final quantum of development the Neighbourhood Plan area is likely to be required to accommodate, especially given the objections to the emerging Local Plan regarding SODC reliance upon sites currently in the Green Belt and sites where their deliverability/sustainability is highly questionable (for example Chalgrove Airfield).

3.11 Given the area’s role as a higher tier settlement in the District, and thereby the optimum location for new development as part of the housing objectives for the District, it is highly likely that an increased proportion of the District’s needs will need to be accommodated at the settlement should the Inspector establish that additional or alternative land be released for development.

3.12 Depending on the outcomes of the Local Plan examination, there is a clear risk that additional sources of supply will be required and currently the Plan does not allow flexibility to enable this to occur. And given the exhaustion of brownfield land within the Neighbourhood Plan Area, this would inevitably need to be catered for on new greenfield release.

3.13 We would also note that the Court of Appeal confirmed in the recent R(DLA Delivery) v Lewes DC ([2017] EWCA Civ 58):

“If a neighbourhood development plan has been made and the local planning authority later produces a development plan document containing new “strategic policies”, that development plan document will, under section 38(5) of the 2004 Act, prevail over any inconsistent policies in the neighbourhood development plan. And if a policy in a neighbourhood development plan is not, or ceases to be, up-to-date, this will be a material consideration in a development control decision, and may justify departing from that policy.”

3.14 In summary if the Neighbourhood Plan were to be made, subject to alterations being made in order to meet the basic conditions as outlined in this response, the Plan will in any event be replaced by the later development plan document in the near future.

3.15 As a result, should the local plan examination identify that additional land is required and thereby allocate / apportion further land / requirement at Wallingford, the Neighbourhood Plan would in essence be out of date soon after adoption. Work on the Neighourhood Plan should be paused until that process is complete.

The making of the neighbourhood plan contributes to the achievement of sustainable development

3.16 A draft Neighbourhood Plan only meets the basic conditions if, inter alia, “the making of the Plan contributes to the achievement of sustainable development”, see paragraph 8(2)(d) of Schedule 4B TCPA 1990.

3.17 The presumption in favour of sustainable development runs through the whole of national planning policy. This is manifested particularly in paragraph 11 of the NPPF. This states that for Plan making:

“a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

3.18 There is a two stage process to achieving sustainable development, firstly the assessment of objective needs for an area and, secondly, a determination whether the impact of meeting those needs would significantly and demonstrably outweigh the benefits.

3.19 For a neighbourhood plan to contribute to meeting sustainable development it must deliver, inter alia, the housing required as a result of that two stage process.

3.20 Thus, neighbourhood plans are required to support the strategic development needs identified by Local Planning Authorities. In other words for a neighbourhood plan to be sustainable it too must meet the objectively assessed needs of the area as identified in an up to date Local Plan.

3.21 A neighbourhood plan that does not meet the objectively assessed needs of the area to which it relates cannot be a plan that contributes to the achievement of sustainable development. For the reasons set out above, the final scale of housing that the Plan area will be required to meet in order to achieve sustainable development is currently unknown. And there is a clear risk due to objections to the emerging Local Plan that the Plan will need to deliver additional development.

3.22 The draft NP should be set aside and a new draft prepared alongside SODC Local Plan once this has passed through examination, in accordance with the advice in the NPPG. In this way a NP can be brought forward which is consistent with national policy and the strategic policies of the emerging Local Plan.

8(2)(e) The making of the neighbourhood plan is in general conformity with the strategic policies contained in the development plan for the area

3.23 It is clear that the preparation of the draft Neighbourhood Plan in running in tandem with the emerging Local Plan.

3.24 Whilst it is generally possible for a Neighbourhood Plan to be progressed in advance of the corresponding Local Plan this does present certain and inevitable problems in terms of meeting the basic conditions and legal compliance tests. These problems are clearly evident in the Neighbourhood Plan as drafted, as highlighted above.

3.25 The Neighbourhood Plan correctly confirms at paragraph 1.1.5 that:

“This Plan is prepared in accordance with Government guidance in the Planning Practice Guidance. It is accordance with policies in the National Planning Policy Framework, and all references within the Wallingford Neighbourhood Plan refer to the February 2019 version of the NPPF. It is in general accordance with strategic policies in the South Oxfordshire District Council (SODC) Core Strategy and Saved policies from the Local Plan 2011 and accompanying evidence documents. SODC is preparing a new Local Plan up to 2034 which was submitted for examination in March 2019 and the Wallingford Neighbourhood Plan (WNP) is consistent with the strategic policies of this Emerging Local Plan (ELP).”

3.26 The NP has therefore consciously not been prepared in sole conformity with the strategic policies contained in the Development Plan. This immediately fails one of the key basic conditions (Paragraph 074 Reference ID: 41-074-20140306 of the NPPG refers).

3.27 This approach is ill conceived because it has resulted in a draft NP that neither conforms with the adopted Local Plan strategic policies and potentially nor the emerging draft Local Plan. The draft NP therefore fails on all levels to be in general conformity with the Development Plan and as a consequence fails the key test of meeting the basic conditions and cannot therefore be regarded as being legally compliance under the terms of the Town and Country Planning Act 1990 (As Amended) and the Neighbourhood Planning (General) Regulations 2012.

3.28 The Council cannot therefore possibly proceed with the Examination of the draft NP given such a fundamental failing in terms of meeting the basic conditions.

3.29 With regard to the emerging Local Plan this is, by definition, not part of the adopted Development Plan and therefore not part of the basic conditions. Notwithstanding this the draft NP fails to be in general conformity with it for a number of reasons including:

 The level and apportionment of housing provision has yet to be set through the emerging Local Plan, with the Neighbourhood Plan prematurely setting what it considers is a reasonable proportion of development. Given our clients significant concerns with the level of housing identified through the emerging Local Plan this is a significant risk to the progression of the NP.

3.30 The Group should therefore accept that it needs to await further progress on the emerging Local Plan before proceeding further. This is of particular importance given Berkeley Strategic’s objections to the emerging TDC Local Plan.

4. Conclusion

4.1 For the reasons set out above, the draft NP does not come close to meeting the basic conditions on numerous grounds. As a neighbourhood plan it is fundamentally flawed.

4.2 The Neighbourhood Plan Group should await the outcome of the examination of the emerging Local Plan before progressing further, namely due to the significant concerns surrounding the proposed release of Green Belt land and the deliverability of the housing supply.

4.3 It needs to be based upon a robust evidence base and a proper, robust and transparent assessment of the suitability, availability and achievability of housing sites in accordance with the NPPF and national guidance.

4.4 Overall, it is considered that the Neighbourhood Plan needs significant work before progressing further. Our client is willing to engage with the Neighbourhood Plan Group and assist in the delivery of a sound Neighbourhood Plan.

Turley Office The Pinnacle 20 Tudor Road Reading RG1 1NH

T 0118 902 2830

Title

Name Taylor Cherrett

Job title (if relevant) Associate Director

Organisation (if relevant) Turley

Organisation representing (if relevant) David Wilson Homes

Address line 1 The Pinnacle

Address line 2 20 Tudor Road

Address line 3

Postal town Reading

Postcode RG1 1NH

Telephone number 01189022830

Email address [email protected] Response 13

Respondent Details

Information

Respondent Number: 13 Respondent ID: 146416664 Date Started: 12/08/2020 12:02:25 Date Ended: 12/08/2020 12:21:32 Time Taken: 19 minutes 6 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from Historic England.

Q3. You can upload supporting evidence here.

File: Historic England 11.08.2020.pdf

Your details and future contact preferences Tobutt, Robyn

From: Lloyd Sweet, Robert Sent: 11 August 2020 23:49 To: Planning Policy South Subject: Fw: Your comments are invited on the Wallingford Neighbourhood Plan

To whom it may concern:

Thank you for consulting Historic England on the submission version of the Wallingford Neighbourhood plan. Historic England is the government’s advisor on planning for the historic environment, including advising on the conservation and enhancement of heritage assets and champion good design in historic places. As such we will comment only on those areas that fall within our remit and silence on other matters should not be treated as agreement or consent. We hope the following comments are of assistance to the examiner

In general we feel that the Wallingford Neighbourhood Plan provides a highly detailed and considerate approach to the need to integrate the conservation of the historic environment into the planning process and provides considerable added value for the specific heritage requirements of the neighbourhood plan area in order to guide decision making, including the implementation of national and local plan policy at the neighbourhood level. It is Historic England's view that Wallingford stands out as a focus of nationally significant heritage assets, particularly in relation to the value of the remains of the Alfredian burh as evidence of the resurgence of the Kingdom of Wessex in the late 9th century and the unification of Wessex and Mercia in the early stages of creation of the English nation. The town and Norman castle were also significant during the Norman conquest and the post conquest period as a key point in the network of Norman Royal power bases.

However, sadly, it is both the scheduled monuments of the burh (town) at the Bull Croft and Kine Croft and the castle that have been identified as 'at risk' monuments on Historic England's Heritage At Risk register (which is formally recognised by DCMS and the ONS). We feel the consideration of these as requiring a particular focus in the Section of heritage policies is helpful in providing recognition of the need to ensure that development of the area helps to sustain the significance of its most precious heritage assets. However, we are concerned that the current policy HA4 may not be implementable, where this is considered to be an additional imposition, on top of CIL charges, or where it could create unforeseen difficulty if it encourages additional development on sites that may not be able to sustainably accommodate it. For example, we could see that it might encourage additional development at Site E at the expense of nationally important archaeological sites in one location, in order to benefit nationally important sites in another.

Our feeling is rather that the policy should support the principal of proposals that can be shown to have benefits for the management and improvement of facilities within these key public open spaces, including supporting enhanced management of the heritage assets, which might include management of foliage, consolidation and conservation of earthworks and masonry elements of ruins and improved public access and interpretation. We would also support this being identified in a schedule of appropriate and necessary CIL funded works that would offset the anticipate additional impacts on these public spaces and heritage assets resulting from the town's growth and increased population.

With regard to site assessments and allocations, we support the inclusion of additional policy requirements to protect the sites of archaeological interest within Site E to guide consideration of reserved matters and, in particular, the requirement for a management pan for open space that 1 will retained to preserve the Bronze Age ring ditch sites in order to prevent development of scrub (policy WS2.2(h)). Development of this site is anticipated to result in loss of considerable areas of other non-designated archaeological remains, including prehistoric trackways, field systems and evidence of settlement and the justification of this loss on the grounds of public benefits that would be delivered should include the potential to provide enhancement of the site's heritage assets for the benefit of the community through interpretation. This is necessary to ensure that the conflict between the proposed development and conservation of the site's archaeological interest is avoided or minimised and that the potential for the development to contribute to local character is appropriately realised. Whilst the incorporation of the remains into an area of landscaped public open space would clearly be desirable it is necessary to guide proposals to avoid landscaping works that could harm the non-designated site - which would not otherwise be protected through scheduled monument status, for example. We would encourage the examiner to consider whether the requirement to protect the areas of archaeological interest during the construction phase set out at 2.4.23 should also be included in the policy, given the potential impact of site stripping, creation of plant transit and storage areas or development of scrub during an extended period of development.

We feel that the relatively cursory consideration given to the mitigation required for impacts to sites of archaeological interest within the consideration of the plan's impacts on the historic environment in the Environmental Report, fails to demonstrate understanding of the relevance of these matters and paints an overly optimistic assessment of the site allocations and the plan as a whole's impacts on the historic environment, but this does not detract from our assessment of the plan as a whole.

We hope these comments are of assistance to the examiner but would be pleased to answer any queries that may arise from them.

Yours faithfully

Robert Lloyd-Sweet

From: South Oxfordshire District Council [mailto:[email protected]] Sent: 16 June 2020 11:02 To: South East ePlanning Subject: Your comments are invited on the Wallingford Neighbourhood Plan

THIS IS AN EXTERNAL EMAIL: do not click any links or open any attachments unless you trust the sender and were expecting the content to be sent to you Dear Sir/Madam

Wallingford Town Council is working on a neighbourhood plan, which has recently been submitted to South Oxfordshire District Council (SODC).

The submitted draft plan and supporting documents were due to undergo a consultation in March, known as the publicity period. However, in response to the Coronavirus (COVID-19) measures put 2 in place by government, the consultation was postponed. Normally the plan and supporting documents are available for people to view in public spaces such as council offices, and village and town halls as well as online. However these buildings are closed and we had difficulty in identifying locations where this information could be made available to the public. In the meantime, the submitted draft plan and supporting documents have been available to read on our website and we have now found alternative locations where paper documents can be viewed easily while still observing social distancing.

As government measures are beginning to be relaxed, we have opened the consultation and are now inviting your comments on the draft plan and supporting documents. Due to the continued COVID-19 restrictions, and the school holidays, the consultation, which would normally run for six weeks, will run for eight weeks from Tuesday 16 June to midnight on Tuesday 11 August 2020.

You can view the neighbourhood plan and supporting documents on our website.

Paper copies are available to view at the following locations:

Location Opening Times Monday – Saturday 8am - KP Stationers, 18A Market Place, 1pm and 2pm - 5pm Wallingford, OX10 0AD Sunday 8am - 11am and 12pm - 3pm Monday – Saturday 6am - Londis, 38 Sinodun Road, 8pm Wallingford, OX10 8AB Sunday 6am - 1pm

Our office at Milton Park is closed to the public until further notice. Please contact us on 01235 422425 or email [email protected] to get support to access the consultation materials.

If you know anyone you think would be interested in this consultation, who is shielding or does not have access to the internet, we would appreciate your help in telling them about it. Please ask them to call us on 01235 422425 or email [email protected] to discuss the proposals and get support to access the consultation materials.

How to comment

We encourage you to use our online comment form available here: https://survey.southandvale.gov.uk/s/WallingfordNP/?m=46039944bredz

The link above is uniquely tied to this survey and to your email address. If you would like to forward this message to any interested parties, please refer them to the neighbourhood planning page where there is a public link to the survey.

Comments can also be made by:  emailing [email protected]  writing to SODC at the following address: 135 Eastern Avenue, Milton Park, Milton, OX14 4SB  completing a comment form (available on request) and posting or emailing it back to us Next steps

After the publicity period ends, your response will be sent to an independent examiner to consider. As the neighbourhood planning process includes an independent examination of the plan, your

3 name, postal address and email (where applicable) are required for your comments to be considered by the examiner. The opportunity for further comments at this stage would only be at the specific request of the examiner.

Most neighbourhood plans are examined without the need for a public hearing. If you think the neighbourhood plan requires a public hearing, you can state this in your comments, but the examiner will make the final decision.

Please clearly state in your comments if you wish to be notified of our decision on whether we formally adopt the neighbourhood plan.

All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published in the final Examiner’s Report on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Thank you in advance for your participation. If you have any questions, please contact [email protected] or call 01235 422425.

Kind regards

Jessica Wilmshurst Assistant Consultation and Community Engagement Officer South Oxfordshire District Council

We are the public body that helps people care for, enjoy and celebrate England's spectacular historic environment, from beaches and battlefields to parks and pie shops. Follow us: Facebook | Twitter | Instagram Sign up to our newsletter

This e-mail (and any attachments) is confidential and may contain personal views which are not the views of Historic England unless specifically stated. If you have received it in error, please delete it from your system and notify the sender immediately. Do not use, copy or disclose the information in any way nor act in reliance on it. Any information sent to Historic England may become publicly available. We respect your privacy and the use of your information. Please read our full privacy policy for more information.

______Opt out: If you do not wish to receive further emails like this from us, please click the link below, and you will be removed from our consultation mailing list. Please note, we may still need to contact you for certain consultations if we have a legal obligation to do so. http://survey.southandvale.gov.uk/s/Remove/

4 Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title Mr

Name Robert LloydSweet

Job title (if relevant)

Organisation (if relevant) Historic England

Organisation representing (if relevant)

Address line 1 Cannon Bridge House

Address line 2 25 Dowgate Hill

Address line 3

Postal town London

Postcode EC4R 2YA

Telephone number 07825907288

Email address [email protected] Response 14

Respondent Details

Information

Respondent Number: 14 Respondent ID: 146418166 Date Started: 12/08/2020 12:27:15 Date Ended: 12/08/2020 12:37:32 Time Taken: 10 minutes 16 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Agent

Your comments

Response received below via email from Avison Young on behalf of National Grid.

Q3. You can upload supporting evidence here.

File: National Grid 29.06.20 Wallingford NP.pdf

Your details and future contact preferences

Central Square South Orchard Street Newcastle upon Tyne NE1 3AZ

Our Ref: MV/ 15B901605 T: +44 (0)191 261 2361 F: +44 (0)191 269 0076

29 June 2020 avisonyoung.co.uk

South Oxfordshire District Council [email protected] via email only

Dear Sir / Madam Wallingford Neighbourhood Plan Regulation 16 Consultation June – August 2020 Representations on behalf of National Grid

National Grid has appointed Avison Young to review and respond to Neighbourhood Plan consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.

About National Grid National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. The energy is then distributed to the electricity distribution network operators across England, Wales and Scotland.

National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.

National Grid Ventures (NGV) is separate from National Grid’s core regulated businesses. NGV develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States.

Proposed development sites crossed or in close proximity to National Grid assets: An assessment has been carried out with respect to National Grid’s electricity and gas transmission assets which include high voltage electricity assets and high-pressure gas pipelines.

National Grid has identified that it has no record of such assets within the Neighbourhood Plan area.

National Grid provides information in relation to its assets at the website below.

• www2.nationalgrid.com/uk/services/land-and- Avison Young is the trading name of GVA development/planning-authority/shape-files/ Grimley Limited registered in England and Wales number 6382509. Registered office, 3 Brindleyplace, Birmingham B1 2JB

Please also see attached information outlining guidance on Regulated by RICS development close to National Grid infrastructure. National Grid 29 June 2020 Page 2

Distribution Networks Information regarding the electricity distribution network is available at the website below: www.energynetworks.org.uk

Information regarding the gas distribution network is available by contacting: [email protected]

Further Advice Please remember to consult National Grid on any Neighbourhood Plan Documents or site-specific proposals that could affect our assets. We would be grateful if you could add our details shown below to your consultation database, if not already included:

Matt Verlander, Director Spencer Jefferies, Town Planner [email protected] [email protected]

Avison Young National Grid Central Square South National Grid House Orchard Street Warwick Technology Park Newcastle upon Tyne Gallows Hill NE1 3AZ Warwick, CV34 6DA

If you require any further information in respect of this letter, then please contact us.

Yours faithfully,

Matt Verlander MRTPI Director 0191 269 0094 [email protected] For and on behalf of Avison Young

avisonyoung.co.uk National Grid 29 June 2020 Page 3

Guidance on development near National Grid assets National Grid is able to provide advice and guidance to the Council concerning their networks and encourages high quality and well-planned development in the vicinity of its assets.

Electricity assets Developers of sites crossed or in close proximity to National Grid assets should be aware that it is National Grid policy to retain existing overhead lines in-situ, though it recognises that there may be exceptional circumstances that would justify the request where, for example, the proposal is of regional or national importance.

National Grid’s ‘Guidelines for Development near pylons and high voltage overhead power lines’ promote the successful development of sites crossed by existing overhead lines and the creation of well-designed places. The guidelines demonstrate that a creative design approach can minimise the impact of overhead lines whilst promoting a quality environment. The guidelines can be downloaded here: https://www.nationalgridet.com/document/130626/download

The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. Where changes are proposed to ground levels beneath an existing line then it is important that changes in ground levels do not result in safety clearances being infringed. National Grid can, on request, provide to developers detailed line profile drawings that detail the height of conductors, above ordnance datum, at a specific site.

National Grid’s statutory safety clearances are detailed in their ‘Guidelines when working near National Grid Electricity Transmission assets’, which can be downloaded here:www.nationalgridet.com/network-and-assets/working-near-our-assets

Gas assets High-Pressure Gas Pipelines form an essential part of the national gas transmission system and National Grid’s approach is always to seek to leave their existing transmission pipelines in situ. Contact should be made with the Health and Safety Executive (HSE) in respect of sites affected by High-Pressure Gas Pipelines.

National Grid have land rights for each asset which prevents the erection of permanent/ temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally, written permission will be required before any works commence within the National Grid’s 12.2m building proximity distance, and a deed of consent is required for any crossing of the easement.

National Grid’s ‘Guidelines when working near National Grid Gas assets’ can be downloaded here: www.nationalgridgas.com/land-and-assets/working-near-our-assets

How to contact National Grid If you require any further information in relation to the above and/or if you would like to check if National Grid’s transmission networks may be affected by a proposed development, please contact:

• National Grid’s Plant Protection team: [email protected]

Cadent Plant Protection Team Block 1 Brick Kiln Street Hinckley LE10 0NA 0800 688 588 or visit the website: https://www.beforeyoudig.cadentgas.com/login.aspx

avisonyoung.co.uk Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title Mr

Name Matt Verlander

Job title (if relevant) Director

Organisation (if relevant) Avison Young

Organisation representing (if relevant) National Grid

Address line 1 Central Square South

Address line 2 Orchard Street

Address line 3

Postal town Newcastle upon Tyne

Postcode NE1 3AZ

Telephone number 01912690094

Email address [email protected] Response 15

Respondent Details

Information

Respondent Number: 15 Respondent ID: 146418818 Date Started: 12/08/2020 12:37:54 Date Ended: 12/08/2020 12:40:12 Time Taken: 2 minutes 18 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from Natural England.

Q3. You can upload supporting evidence here.

File: Natural England 10.08.2020.pdf

Your details and future contact preferences Date: 10 August 2020 Our ref: 319748 Your ref: Wallingford NDP – REG 14

Ms Jessica Wilmshurst South Oxfordshire District Council Hornbeam House 135 Eastern Avenue Crew e Business Park Electra Way Milton Park Crew e Milton Cheshire OX14 4SB CW1 6GJ

BY EMAIL ONLY T 0300 060 3900 [email protected]

Dear Ms Wilmshurst

Wallingford Neighbourhood Plan – REG 14

Thank you for your consultation request on the above dated and received by Natural England on 16th June, 2020 .

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the Parish/Town Councils or Neighbourhood Forums where they consider our interests would be affected by the proposals made.

Natural England does not have any specific comments on this draft neighbourhood plan.

However, we refer you to the attached annex which covers the issues and opportunities that should be considered when preparing a Neighbourhood Plan.

For any further consultations on your plan, please contact: [email protected].

Yours sincerely

Sharon Jenkins Operations Delivery Consultations Team Natural England

Annex 1 - Neighbourhood planning and the natural environment: information, issues and opportunities Natural environment information sources

The Magic1 website will provide you with much of the nationally held natural environment data for your plan area. The most relevant layers for you to consider are: Agricultural Land Classification, Ancient Woodland, Areas of Outstanding Natural Beauty, Local Nature Reserves, National Parks (England), National Trails, Priority Habitat Inventory, public rights of way (on the Ordnance Survey base map) and Sites of Special Scientific Interest (including their impact risk zones). Local environmental record centres may hold a range of additional information on the natural environment. A list of local record centres is available here2. Priority habitats are those habitats of particular importance for nature conservation, and the list of them can be found here3. Most of these will be mapped either as Sites of Special Scientific Interest, on the Magic website or as Local Wildlife Sites. Your local planning authority should be able to supply you with the locations of Local Wildlife Sites. National Character Areas (NCAs) divide England into 159 distinct natural areas. Each character area is defined by a unique combination of landscape, biodiversity, geodiversity and cultural and economic activity. NCA profiles contain descriptions of the area and statements of environmental opportunity, which may be useful to inform proposals in your plan. NCA information can be found here4. There may also be a local landscape character assessment covering your area. This is a tool to help understand the character and local distinctiveness of the landscape and identify the features that give it a sense of place. It can help to inform, plan and manage change in the area. Your local planning authority should be able to help you access these if you can’t find them online. If your neighbourhood planning area is within or adjacent to a National Park or Area of Outstanding Natural Beauty (AONB), the relevant National Park/AONB Management Plan for the area will set out useful information about the protected landscape. You can access the plans on from the relevant National Park Authority or Area of Outstanding Natural Beauty website. General mapped information on soil types and Agricultural Land Classification is available (under ’landscape’) on the Magic5 website and also from the LandIS website6, which contains more information about obtaining soil data. Natural environment issues to consider

The National Planning Policy Framework7 sets out national planning policy on protecting and enhancing the natural environment. Planning Practice Guidance8 sets out supporting guidance. Your local planning authority should be able to provide you with further advice on the potential impacts of your plan or order on the natural environment and the need for any environmental assessments.

1 http://magic.defra.gov.uk/ 2 http://www.nbn-nfbr.org.uk/nfbr.php 3http://webarchive.nationalarchives.gov.uk/20140711133551/http:/www.naturalengland.org.uk/ourwork/conservation/biodiv ersity/protectandmanage/habsandspeciesimportance.aspx 4 https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making 5 http://magic.defra.gov.uk/ 6 http://www.landis.org.uk/index.cfm 7https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/807247/NPPF_Feb_2019 _revised.pdf 8 http://planningguidance.planningportal.gov.uk/blog/guidance/natural-environment/

Landscape Your plans or orders may present opportunities to protect and enhance locally valued landscapes. You may want to consider identifying distinctive local landscape features or characteristics such as ponds, woodland or dry stone walls and think about how any new development proposals can respect and enhance local landscape character and distinctiveness. If you are proposing development within or close to a protected landscape (National Park or Area of Outstanding Natural Beauty) or other sensitive location, we recommend that you carry out a landscape assessment of the proposal. Landscape assessments can help you to choose the most appropriate sites for development and help to avoid or minimise impacts of development on the landscape through careful siting, design and landscaping. Wildlife habitats Some proposals can have adverse impacts on designated wildlife sites or other priority habitats (listed here9), such as Sites of Special Scientific Interest or Ancient woodland10. If there are likely to be any adverse impacts you’ll need to think about how such impacts can be avoided, mitigated or, as a last resort, compensated for. Priority and protected species You’ll also want to consider whether any proposals might affect priority species (listed here11) or protected species. To help you do this, Natural England has produced advice here12 to help understand the impact of particular developments on protected species. Best and Most Versatile Agricultural Land Soil is a finite resource that fulfils many important functions and services for society. It is a growing medium for food, timber and other crops, a store for carbon and water, a reservoir of biodiversity and a buffer against pollution. If you are proposing development, you should seek to use areas of poorer quality agricultural land in preference to that of a higher quality in line with National Planning Policy Framework para 171. For more information, see our publication Agricultural Land Classification: protecting the best and most versatile agricultural land13. Improving your natural environment

Your plan or order can offer exciting opportunities to enhance your local environment. If you are setting out policies on new development or proposing sites for development, you may wish to consider identifying what environmental features you want to be retained or enhanced or new features you would like to see created as part of any new development. Examples might include:  Providing a new footpath through the new development to link into existing rights of way.  Restoring a neglected hedgerow.  Creating a new pond as an attractive feature on the site.  Planting trees characteristic to the local area to make a positive contribution to the local landscape.  Using native plants in landscaping schemes for better nectar and seed sources for bees and birds.  Incorporating swift boxes or bat boxes into the design of new buildings.  Think about how lighting can be best managed to encourage wildlife.  Adding a green roof to new buildings.

9http://webarchive.nationalarchives.gov.uk/20140711133551/http:/www.naturalengland.org.uk/ourwork/conservation/biodiv ersity/protectandmanage/habsandspeciesimportance.aspx 10 https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences 11http://webarchive.nationalarchives.gov.uk/20140711133551/http:/www.naturalengland.org.uk/ourwork/conservation/biodiv ersity/protectandmanage/habsandspeciesimportance.aspx 12 https://www.gov.uk/protected-species-and-sites-how-to-review-planning-proposals 13 http://publications.naturalengland.org.uk/publication/35012

You may also want to consider enhancing your local area in other ways, for example by:  Setting out in your plan how you would like to implement elements of a wider Green Infrastructure Strategy (if one exists) in your community.  Assessing needs for accessible greenspace and setting out proposals to address any deficiencies or enhance provision.  Identifying green areas of particular importance for special protection through Local Green Space designation (see Planning Practice Guidance on this 14).  Managing existing (and new) public spaces to be more wildlife friendly (e.g. by sowing wild flower strips in less used parts of parks, changing hedge cutting timings and frequency).  Planting additional street trees.  Identifying any improvements to the existing public right of way network, e.g. cutting back hedges, improving the surface, clearing litter or installing kissing gates) or extending the network to create missing links.  Restoring neglected environmental features (e.g. coppicing a prominent hedge that is in poor condition, or clearing away an eyesore).

14 http://planningguidance.planningportal.gov.uk/blog/guidance/open-space-sports-and-recreation-facilities-public-rights-of- way-and-local-green-space/local-green-space-designation/

Title

Name Sharon Jenkins

Job title (if relevant) Consultation Team

Organisation (if relevant) Natural England

Organisation representing (if relevant)

Address line 1 Hornbeam House

Address line 2 Crewe Business Park

Address line 3 Electra Way

Postal town Cheshire

Postcode CW1 6GJ

Telephone number

Email address [email protected] Response 16

Respondent Details

Information

Respondent Number: 16 Respondent ID: 146419240 Date Started: 12/08/2020 12:43:38 Date Ended: 12/08/2020 12:48:10 Time Taken: 4 minutes 31 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from Network Rail.

Q3. You can upload supporting evidence here.

File: Network Rail 30.07.2020.pdf

Your details and future contact preferences Faludi, Dorottya

From: Lewis Grace Sent: 30 July 2020 15:41 To: Planning Policy South Subject: Wallingford Neighbourhood Development Plan

Follow Up Flag: Follow up Flag Status: Flagged

OFFICIAL

Wallingford Neighbourhood Development Plan

Thank you for consulting Network Rail on the Wallingford Neighbourhood Development Plan. This email forms the basis of our response.

Network Rail is a statutory undertaker responsible for maintaining and operating the country’s railway infrastructure and associated estate. Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan policy is important in relation to the protection and enhancement of Network Rail’s infrastructure.

Policy MC6 – Wallingford Railway Corridor Wallingford Railway Preservation Society (CWRPS) believes that a commercially viable commuter service between Wallingford Railway Station and Chorley may be possible to link the two stations.

As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund rail or station improvements necessitated by commercial development. It is therefore appropriate to require developer contributions to fund such improvements.

We would appreciate the Council’s providing Network Rail with an opportunity to comment on any future planning policy documents. We look forward to continuing to work with you to maintain consistency between local and rail network planning strategy.

We trust these comments will be considered in your preparation of the forthcoming Plan documents.

Yours Sincerely,

Grace Lewis Town Planning Technician Property Network Rail (Wales & Western) 1st Floor | Temple Point | Redcliffe Way | Bristol |BS1 6NL T 07732644491

E [email protected] www.networkrail.co.uk/property

1 ************************************************************************************************** **************************************************************

The content of this email (and any attachment) is confidential. It may also be legally privileged or otherwise protected from disclosure. This email should not be used by anyone who is not an original intended recipient, nor may it be copied or disclosed to anyone who is not an original intended recipient.

If you have received this email by mistake please notify us by emailing the sender, and then delete the email and any copies from your system.

Liability cannot be accepted for statements made which are clearly the sender's own and not made on behalf of Network Rail. Network Rail Infrastructure Limited registered in England and Wales No. 2904587, registered office Network Rail, 2nd Floor, One Eversholt Street, London, NW1 2DN

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2 Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title

Name Grace Lewis

Job title (if relevant) Town Planning Technician

Organisation (if relevant) Network Rail

Organisation representing (if relevant)

Address line 1 Temple Point

Address line 2 Redcliffe Way

Address line 3

Postal town Bristol

Postcode BS1 6NL

Telephone number 07732644491

Email address [email protected] Response 17

Respondent Details

Information

Respondent Number: 17 Respondent ID: 146419551 Date Started: 12/08/2020 12:48:48 Date Ended: 12/08/2020 13:05:20 Time Taken: 16 minutes 32 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Organisation

Your comments

Response received below via email from St Edwards Homes Limited.

Q3. You can upload supporting evidence here.

File: St Edward's 11.08.2020.pdf

Your details and future contact preferences

Planning Policy (Neighbourhood Plans) South Oxfordshire District Council 135 Eastern Avenue Milton Park Milton OX14 4SB

BY EMAIL: [email protected]

11 August 2020

Dear Sir/Madam,

REPRESENTATIONS TO WALLINGFORD NEIGHBOURHOOD PLAN REGULATION 16 CONSULTATION

This submission is made by St Edward Homes Limited (‘St Edward’), in response to the Wallingford Neighbourhood Plan Regulation 16 Consultation (‘WNP’). St Edward has under its control land known as Highcroft, Land to the West of Wallingford (Site B) (‘Highcroft’) identified on the red line boundary at Appendix 1.

Background

St Edward has been actively involved throughout the WNP process, including meeting with the Steering Group and submitting representations to previous consultations, provided at Appendix 2.

Outline planning permission was granted for Highcroft on 04 October 2017 (with all matters except access reserved) for:

“Residential development comprising 555 dwellings, a one form entry primary school, associated landscaping and open spaces, construction of a new access onto the A4130 Calvin Thomas Way/Bosley Way, construction of a public transport link/emergency access onto Wantage Road and other supporting infrastructure works and facilities. (As amended by i) revised drawings and supporting information 16 September 2015; ii) additional information - planting schedule, assessment of Mill Brook and highway information 24 November 2015; iii) revised bus / emergency access onto Wantage Road 9 May 2017 and iv) additional drainage information 6 June 2017).”

Reserved Matters have subsequently been approved for Phase 1 on 14 May 2019 for 125 dwellings (P17/S3891/RM), with a re-plan of 75 dwellings recently gaining approval 20 February 2020 (P19/S2729/RM). All pre-commencement conditions have now been discharged with construction works commencing on Phase 1A in September 2019. Phase 2 of the development for a 75 unit Extra Care Facility (P18/S0068/RM) was granted 08 May 2019.

St Joseph Homes Limited, 9 Colmore Row, Birmingham, B3 2BJ Tel: 0121 200 3500 | www.berkeleygroup.co.uk Registered in England and Wales | Registered: No. 09277367 Registered Office: Berkeley House, 19 Portsmouth Road, Cobham, Surrey KT11 1JG

In addition, separate detailed planning permission for ancillary highway works necessary to deliver the access approved under the outline planning permission was granted on 28 November 2018 (P18/S2617/FUL).

Policy Update

South Oxfordshire Core Strategy 2012 – 2027

The South Oxfordshire Core Strategy (‘CS’) sets out the vision for South Oxfordshire up until 2027. The CS sets out the spatial vision for the District, including strategic objectives such as housing allocations for the Plan period. Strategic Policy CSWAL2 of the CS allocates Highcroft for 555 homes. The following text is included within the CS:

“Permission will be granted for a new greenfield neighbourhood of 555 homes to the west of Wallingford (as shown on the Adopted Policies Map) provided that: (i) The area is planned comprehensively and the development takes place in accordance with an agreed design brief as required by Policy CSQ4; (ii) The form and characteristics of the development meet identified housing needs of Wallingford; (iii) Access is from the western bypass, with no vehicular access provided through Queen’s Avenue; (iv) A through route is provided for public transport; (v) Measures are put in place to mitigate any impacts on the Wallingford Air Quality Management Area; (vi) Safe pedestrian and cycle linkages are provided from the development to the town centre and to Hithercroft; (vii) The western and southern boundaries are reinforced with significant landscape buffers, with no built development along the western boundary adjacent to the bypass; (viii) The existing footpath through the site is developed into a green corridor linking the town to the wider countryside; (ix) Provision is made, or contributions are provided, towards the supporting infrastructure set out in our infrastructure delivery plan including a new primary school.”

Emerging Local Plan 2034

The Emerging Local Plan (‘ELP’) seeks to set out the vision for South Oxfordshire up to 2034. South Oxfordshire District Council (‘SODC’) undertook an initial Regulation 19 consultation in October 2017. However, additional work was required to reassess each of the main housing sites proposed, as well as previously considered sites, due to the uncertainty regarding deliverability. An updated Regulation 19 version was published in January 2019.

On 29 March 2019 the ELP was submitted for independent examination. Since then, there has been several delays, leading to the Secretary of State issuing South Oxfordshire with a Direction to progress the ELP through to examination, to be adopted by December 2020. Virtual Hearing Sessions have been

held from 14 July 2020 - 07 August 2020. At the time of writing, there are no further sessions organised whilst the Inspector awaits further detail from SODC following on from matters discussed.

The ELP relies on Highcroft to come forward and deliver 555 dwellings to meet its housing target. However, despite relying on these numbers the ELP does not include an allocation for Highcroft. To address this discrepancy SODC published a Schedule of Proposed Modifications in March 2019, which at ‘Mod No 38’ states that Policy H3 will be amended to include the following text:

“Land within the allocation at West of Wallingford will be developed to deliver approximately 555 new homes. Proposals will be expected to deliver: i. Access from the western bypass, with no vehicular access provided through Queen’s Avenue and the discouragement of traffic from entering the Wallingford AQMA; ii. The western and southern boundaries are reinforced with significant landscape buffers, with no built development along the western boundary adjacent to the bypass;”

The Local Plan Inspector’s response to the proposed modifications confirms that the additional text relating to Highcroft appears to be justified for soundness and effectiveness, but will need to be included in a schedule of main modifications and subject to public consultation.

Wallingford Neighbourhood Plan Regulation 14 Consultation

St Edward provided representations during the Regulation 14 consultation, and would like to refer back to suggested amendments that have not been reflected in this Regulation 16 consultation. The initial representation was made to assist the Steering Group to comply with the ‘basic conditions’ as set out in at paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990 as applied to neighbourhood plans by section 38A of the Planning and Compulsory Purchase Act 2004.

For clarity, Table 1 includes a summary of previous representations made during the Regulation 14 consultation, and a summary of Regulation 16 representations as to whether they have been upheld.

Table 1: Summary of Reg 14 and Reg 16 Representations Policy Representations by St Edward to Reg 14 WNP Response Representation to this Consultation within Reg 15 Consultation (Reg 16) Consultation Policy WS3 Wording proposed to optimise sites and No change Uphold previous to seek higher densities to be located representations close to public transport Policy Minor amendment to replace ‘provided’ No change Uphold previous HD3.1 to ‘supported’ representations Policy Minor amendment to include No change, new Uphold previous HD3.2(d) ‘indistinguishable in appearance from’ paragraph representations reference from HD3.7 Policy Wording proposed to allow for clusters No change, new Uphold previous HD3.2(e) to accommodate management paragraph representations

reference from HD3.8 Para 3.5.7 Wording proposed regarding SODC No change Uphold previous Housing Mix representations Policy HD4 Minor amendments to the wording of No change Uphold previous the Policy representations Policy MC5 Clarity requested regarding the No change Uphold previous appropriate standards representations Policy Revision of Policy to support the No change Uphold previous MC7.3 inclusion of EV charging points representations

As displayed in Table 1, St Edward uphold their previous representations following on from the Regulation 14 consultation (included within Appendix 2) and request that they are reviewed as a part of this consultation process. Below, St Edward have expanded on the suggested changes where appropriate.

Policy WS3: Housing Density

Housing density within the WNP seeks to provide a minimum of 25 dwellings per hectare on sites of 10 or more homes. However, within the emerging ELP the minimum target on sites located within Wallingford is set at a minimum of 45-60 units. During the ELP examination, participants supported the higher number, with potential to increase to 70dpa. St Edward appreciate that the ELP is still undergoing examination, with an intended date for adoption in December 2020. If no amendments are made to the drafting of this policy, once adopted the WNP will be considered out of date and inconsistent with Local Planning Policy which would therefore mean it does not meet the ‘basic condition’ as it clearly does not support strategic policy1. The proposed amendment below seeks to allow for compliance with Paragraph 122 of the NPPF “planning policies and decisions should support development that makes efficient use of land” and consistency the CS and ELP:

“Proposals for residential development should optimise the capacity of sites. Housing density on new development sites of more than 10 homes shall be a minimum of 25 dwellings per hectare and shall take account of local circumstances, including protection of the local historic environment, landscape, local character and access to services and facilities. Higher densities will be sought where there is access to frequent public transport services and a range of services and facilities.”

Paragraph 2.4.27: The WNP states that the higher level of development is inappropriate for Wallingford. This statement is not compliant with the ELP, therefore, in line with the above, St Edward suggests for consistency to remove the statement.

“We note that SODC in the ELP are looking to achieve minimum densities of 50 units/ha and at Policy DES 8 are looking to achieve a minimum density of between 30 and 50 dwellings per hectare. This is inappropriate for Wallingford. We agree that higher density may be appropriate in more urban areas, but our view is that Wallingford’s rural character, important

1 Paragraph: 074 Reference ID: 41-074-20140306

heritage and proximity to sensitive AONB landscapes needs more flexibility on housing densities. In streets close to submitted housing sites we have found densities to be between 14 and 33 homes per ha. We believe that 10 dwelling units is the minimum number below which density ceases to be meaningful statistical measure.”

Policy HD3: Affordable Housing, Mix of Housing Types and the Avoidance of Segregation

“HD3.1: A mix of housing types and sizes to meet the needs of current and future households will be provided supported within new developments as detailed in South Oxfordshire development plan.

HD3.2(d): integrate affordable housing such that it is inclusive and non- discriminatory in terms of appearance and accessibility with indistinguishable in appearance from the market housing on that site.

HD3.2(e): does not isolate affordable housing, nor concentrate it in clusters of more than 15 dwellings or 10% of the development total whichever is smaller, unless it is necessary for management purposes or to address local authority/registered provider requirements.”

Paragraph 3.5.7: In connection with the requested changes to draft Policy HD3 in relation to housing mix, we would request that the following text be added to paragraph 3.5.7 to explain that SODC’s housing need evidence will inform housing mix.

“A wide mix of housing types is needed in order to meet the requirements and aspirations of the community by increasing the option for housing mobility within the town. The housing mix in development shall have regard to South Oxfordshire District Council’s latest evidence of need.”

Policy HD4: Self Build

St Edward would like to emphasise the point to the Inspector, although self-build and/or custom build plots are important in meeting specialist need, there is no evidence to suggest there is a local need in Wallingford. Currently, Policy HD4 is seeking new developments of 10 or more dwellings to include provision for self-build and/or custom build plots. Evidence should be provided to support this inclusion. St Edward suggest the following amendments to allow for flexibility:

“New housing development proposals of more than 10 dwellings should include that make provision for self-build and/or custom-build plots will be supported.”

Policy MC5: Vehicle Parking

St Edward are still concerned with the wording of Policy MC5, paragraphs MC5.1 and MC5.2 still do not make it clear exactly which standards should be followed. Paragraph MC5.1 states that ‘new housing proposals should meet the requirement in Oxfordshire County Council’s Residential Parking Provision Policy’. However, Paragraph MC5.2 then states ‘on sites of 10 or more homes parking spaces should be provided at least in accordance with the above requirements’. The standards provided seem

to exceed the minimum standards as required by the County Council, and does not illustrate exactly what standards an Applicant should follow. This approach undermines the CS and ELP objectives to promote sustainable modes of travel. Currently, this Policy does not meet the basic conditions by way of conflicting with strategic policy.

St Edward suggest the removal of the minimum standards included within the Policy and reflect the Oxfordshire County Council residential parking standards.

Policy MC7: Electric Vehicle Charging for Residents, Employees and Visitors

St Edward reiterates the point regarding the reality of the use of charging points. Realistically, on development sites such as Site B, bus stops will be used by future residents or those living in close proximity, therefore not needing to use these points. If one point is provided for every five bicycle spaces, this will wasted on future residents who will not require them. Additionally, requesting a charging point for every five bicycle spaces, will have significant implications on the viability of large development proposals. The suggestion for the re-wording is put forward:

“MC7.3: Provision of EV charging points for public bicycle parking in new residential developments will be supported All new residential developments with public bicycle storage will provide at least one EV charge point for every five bicycle spaces.”

Conclusion

St Edward still has concerns regarding whether the ‘basic conditions’ have been met following on from the Regulation 14 consultation, due to the inconsistencies with the NPPF and conflicts with the policies of the CS and ELP (conditions a and e), and failing to contribute to the achievement of sustainable development (condition d). It is respectfully asked that the Inspector considers the suggested amendments to the wording of certain policies as included within these representations.

St Edward praise the work undertaken by the Steering Group, and appreciate the opportunity to influence the WNP. We look forward to working with Wallingford Town Council on future planning applications at Highcroft, Wallingford.

Please may we have notification, by email, of the Local Authority’s decision on whether the WNP is made.

Should any further information be required, please get in touch through the below contact details.

Yours sincerely,

Polly Mathews Assistant Development Manager [email protected]

APPENDIX 1

Highcroft, Land to the West of Wallingford (Site B) Red Line Boundary

APPENDIX 2

St Edward Regulation 14 Consultation Response 16 October 2019

Mayfield House 256 Banbury Road Oxford Wallingford Neighbourhood Plan Consultation OX2 7DE Wallingford Town Council T: 01865 511444 9 St Martin’s Street Wallingford F: 01865 310653 Oxfordshire OX10 0AL Your ref: Our ref: BY EMAIL: [email protected]

16 October 2019

Dear Sirs

WALLINGFORD NEIGHBOURHOOD PLAN REGULATION 14 CONSULTATION

This submission is made on behalf of St Edward Homes Limited (‘St Edward’), in response to the Wallingford Neighbourhood Plan Regulation 14 consultation (WNP).

We are grateful to the Wallingford Neighbourhood Plan Steering Group for taking the time to meet with us on 3 October 2019. The helpful comments made by the Steering Group have informed this submission.

1.0 Introduction

1.1 St Edward is part of the Berkeley Group and has under its control land known as ‘Land to the West of Wallingford (Site B)’, identified on the red line plan provided at Appendix 1. They will be responsible for delivering the development that secured planning permission in 2017.

1.2 Policy CSWAL2 of the South Oxfordshire Core Strategy (CS) allocates the site for 555 homes. The version of the emerging Local Plan 2034 (ELP)1 submitted to the Secretary of State on 29 March 2019 relies on this allocation to meet its housing target. However, despite relying on these numbers the ELP does not include an allocation for the site. To address this discrepancy South Oxfordshire District Council (SODC) published a Schedule of Proposed Modifications in March 2019, which at ‘Mod No 38’ states that Policy H3 will be amended to include the following text:

1 Local Plan 2011-2034 Final Publication Version (2nd) dated January 2019

4167303v1

1.3 The Local Plan Inspectors response to the proposed modifications2 confirms that the additional text relating to the site appears to be justified for soundness and effectiveness, but will need to be included in a schedule of main modifications and subject to public consultation.

1.4 Outline planning permission was granted for the site on 4 October 2017 (with all matters except access reserved) for:

1.5 Reserved Matters have subsequently been approved for Phase 13 and Phase 24. Construction works commenced on Phase 1 in September 2019.

1.6 In addition, separate detailed planning permission for ancillary highway works necessary to deliver the access approved under the outline planning permission was granted on 28 November 2018 (reference: 18/S2617/FUL).

2.0 Comments on Wallingford Neighbourhood Plan Document

2.1 Planning Practice Guidance states that to proceed to a referendum a draft Neighbourhood Plan must meet the ‘Basic Conditions’ set out at paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990 as applied to neighbourhood plans by section 38A of the Planning and Compulsory Purchase Act 2004.5

2.2 To assist the Neighbourhood Plan Steering Group as it prepares its Regulation 15 submission, we have considered the WNP against the basic conditions.

2.3 Where this submission has respectfully suggested to the Steering Group that amendments to the WNP are necessary to comply with the ‘basic conditions’, the proposed new text is underlined and deleted text is struck through.

Timing

2.4 The WNP explains at paragraph 1.1.5 that it is in general accordance with the CS and Saved Policies in the South Oxfordshire Local Plan 2011 (LP). It adds that the WNP is also consistent with the strategic polices of the emerging Local Plan 2034 (ELP).

2 Inspectors’ comments on the Council’s “Schedule of Modifications” (Document CSD13) 3 Reserved Matters for Phase 1comprising the construction of 125 dwellings, landscaping, sports pitches, allotments, estate roads and associated infrastructure granted on 14 May 2019 (ref: P17/S3891/RM) 4 Reserved Matters for Phase 2 comprising the construction of a 75 unit Extra Care Facility and provision of the Central Square including a Locally Equipped Play Area (LEAP) with associated parking, landscaping and infrastructure provision granted 8 May 2019 (ref: P18/S0068/RM) 5 PPG Paragraph: 065 Reference ID: 41-065-20140306

Page 2 of 6 4167303v1

2.5 The strategic policies in the CS are based on the revoked South East Plan (SEP)6 and are therefore out of date. The National Planning Policy Framework (NPPF) states at paragraph 33 that Local Plans and strategic policies should be reviewed every five years. This review is taking place and based on up to date evidence the ELP focuses growth at Didcot and Culham, as well as at strategic allocations close to Oxford.

2.6 However, there is considerable uncertainty surrounding the future of the ELP, as a result of its growth strategy, and associated strategic policies. SODC has not reached a decision whether to proceed with the ELP and as a consequence the Secretary of State is considering whether to exercise his powers under the Planning and Compulsory Purchase Act 2004 which would require the ELP to be submitted to him for approval.

2.7 The Planning Practice Guidance advises that when considering whether a neighbourhood plan meets the basic condition to be in general conformity with the Local Plan, an examiner must have regard to:

 whether the neighbourhood plan policy supports and upholds the general principle that the strategic policy is concerned with;  the degree, if any, of conflict between the draft neighbourhood plan policy and the strategic policy;  whether the draft neighbourhood plan policy provides an additional level of detail and/or a distinct local approach to that set out in the strategic policy without undermining that policy;  the rationale for the approach taken in the draft neighbourhood plan and the evidence to justify that approach7

2.8 Given the age of the CS and its evidence base, and the uncertainty surrounding the ELP, we would suggest that submission of the WNP be delayed until such time as there is greater confidence about the future of the ELP.

Policy WS3: Housing Density

2.9 The NPPF states that planning policies should support efficient use of land8. Although Policy WS3 broadly accords with the approach in CS Policy CSH2, we would suggest that the wording be amended to more clearly align with the CS and the NPPF. This would also reflect the direction of travel in the ELP as regards density. On this basis we would request that the following text be added:

6 South East Plan, adopted May 2009 7 PPG Paragraph 074 Reference ID: 41-074-20140306 8 NPPF, paragraph 122

Page 3 of 6 4167303v1

Chapter 3 – Housing, Design & Character Assessment

Policy HD3: Affordable Housing, Mix of Housing Types and the Avoidance of Segregation

2.10 The NPPF states that the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies9. This is reflected in CS Policy CSH4 and in ELP Policy H11, both of which require new development to provide a mix of dwelling types and sizes to meet the needs of current and future households.

2.11 The Berkeley Group has a record of delivering high quality places that are well-integrated with existing communities. They ensure housing is tenure neutral and evenly distributed across sites to promote community cohesion. St Edward therefore welcomes the WNP’s aspiration that affordable housing is not isolated. However, from their considerable experience of housing delivery and working with registered providers, they would suggest that Policy HD3.8 could impose a restriction that may not in practice be deliverable in all cases. For example, in apartment blocks where a mix of social rent and market products sharing cores would typically present management complications for registered providers.

2.12 On this basis we would request that the following text be added to Policy HD3:

“HD3.1 A mix of housing types and sizes to meet the needs of current and future households will be provided supported within new developments. as detailed in South Oxfordshire development plan.

HD3.7 integrates affordable housing such that it is inclusive and non- discriminatory in terms of appearance and accessibility with indistinguishable in appearance from the market housing on that site.

HD3.8 does not isolate affordable housing, nor concentrate it in clusters of more than 15 dwellings or 10% of the development total whichever is smaller, unless it is necessary for management purposes or to address local authority/registered provider requirements.”

Paragraph 3.5.7

2.13 In connection with the requested changes to draft Policy HD3 in relation to housing mix, we would request that the following text be added to paragraph 3.5.7 to explain that SODC’s housing need evidence will inform housing mix.

Policy HD4: Self Build

2.14 Paragraph 61 of the NPPF states that in assessing the housing needs of a community, specialist need should be considered, which includes people wishing to commission or build their own homes.

9 NPPF, paragraph 61

Page 4 of 6 4167303v1

2.15 Draft Policy HD4 states that development of 10 or more dwellings should include self-build and/or custom build plots. As required by paragraph 61 of the NPPF the housing need of different groups should be assessed in preparing planning policies. The WNP housing needs assessment10 does not provide any evidence of local need for self or custom build.

2.16 However, the Oxfordshire Strategic Housing Market Assessment (SHMA) (April 2014) considers specialist housing needs across the County and in relation to self and custom building states that:

“Overall the evidence we have collected across England, and looking more specifically at Oxfordshire, suggest that this is a niche sector, but one that is not necessarily only delivering high value bespoke homes. It is clear that much activity is undertaken by entrepreneurs aimed at more modest homes for sale or rent and in doing so making better use of land that may detract from the local environment.11”

“In policy terms there is some potential to encourage through policy developers of larger schemes to designate parts of the scheme as serviced plots which can be developed as self-build. There is some, albeit limited evidence of this. It is difficult to demonstrate concrete evidence of demand.12”

2.17 Whilst St Edward recognises the importance of meeting specialist need, there is no evidence to suggest that there is local need in Wallingford for self and custom build plots. We would therefore request that the following text be added to Policy HD4 to allow greater flexibility and to reflect the evidence base:

“New housing development proposals of more than 10 dwellings should include that make provision for self-build and/or custom-build plots will be supported.”

Chapter – Movement and Connectivity

Policy MC5: Vehicle Parking

2.18 Although the NPPF discourages the use of maximum parking standards, at its heart is the objective to promote sustainable modes of transport and adoption of travel solutions which support reductions in greenhouse gas emissions and reduce congestion through promotion of walking and cycling.

2.19 The proposed minimum parking standards at Policy MC5 has been informed by 2011 Census data which records the percentage of households that own one or more vehicles.

2.20 The table in Policy MC5 is not clear in what standard it is asking developers to apply, i.e. the County Council standards or those set out in the table. The table headings are also unclear, however, we have assumed that the left hand column is for one allocated space and remainder unallocated off-road and the right hand column should read two allocated spaces and the remainder unallocated off-road13.

2.21 The standards in Policy MC5 appear to exceed the minimum standards applied by the County Council, specifically in relation to 3, 4 and 4+ bedroom properties. St Edward are of the view that setting a higher minimum parking standard would place a considerable constraint on development that may have negative impacts in terms of quality of place. Furthermore, the approach undermines the

10 Housing Needs Assessment Wallingford, South Oxfordshire – Final Report April 2019 (prepared by Chameleon Consultancy) 11 SHMA, paragraph 8.84 12 SHMA, paragraph 8.85 13 Both allocated and unallocated required to be provided off-road

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Government’s objective to promote sustainable modes of travel. It is this objective, and not 2011 trends towards car ownership, that should inform car parking policy.

2.22 A lower minimum standard would not prevent the Town or District Council from seeking higher levels of car parking in appropriate locations, based on the proximity of a site to local services and availability to alternative modes of travel.

2.23 On this basis, we would request that Policy MC5 be amended to reflect the Oxfordshire County Council residential parking standards.

Policy MC7: Electric Vehicle Charging for Residents, Employees and Visitors

2.24 Draft Policy MC7.3 requires one EV charging point for every five public cycle parking spaces. While St Edward supports the ambition of this policy, the practicality of its application is not clear. Development of the scale at Site B will incorporate bus stops which will require public cycle parking. However, in reality these stops will be utilised by future residents or those living close by. As such, we would question whether in practice the charging points would be used.

2.25 In the absence of any evidence to demonstrate demand for such technology we would request that the following text be added to Policy MC7 to provide greater flexibility:

MC7.3 Provision of EV charging points for public bicycle parking in new residential developments will be supported All new residential developments with public bicycle storage will provide at least one EV charge point for every five bicycle spaces.

Conclusion

2.26 For the reasons given above, the WNP and its evidence would fail to meet the ‘basic conditions’ in that it is inconsistent with the NPPF and conflicts with the strategic policies of the CS and ELP. In order to meet the ‘basic conditions’ this submission has respectfully suggested amendments to the wording of certain policies.

2.27 Furthermore, in light of the current uncertainty surrounding the ELP and its strategic policies St Edward would suggest that submission is delayed until there is clarity regarding the future of the ELP.

2.28 St Edward is pleased to have been able to contribute to this consultation and looks forward to constructively engaging in future consultations as the neighbourhood plan process progresses.

Yours faithfully,

Steven Roberts Associate

E: [email protected] T: 01865 404401 M: 07801 666142

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Title

Name Polly Mathews

Job title (if relevant) Assistant Development Manager

Organisation (if relevant) St Edward Homes Limited

Organisation representing (if relevant)

Address line 1 9 Colmore Row

Address line 2

Address line 3

Postal town Birmingham

Postcode B3 2BJ

Telephone number 01212003556

Email address [email protected] Response 18

Respondent Details

Information

Respondent Number: 18 Respondent ID: 146421814 Date Started: 12/08/2020 13:11:16 Date Ended: 12/08/2020 13:21:28 Time Taken: 10 minutes 12 seconds Translation: English IP Address: Country: United Kingdom

Q1. Are you completing this form as an:

Agent

Your comments

Response received below via email from Savills on behalf of Thames Water.

Q3. You can upload supporting evidence here.

File: Thames Water 10.08.2020.PDF Download

Your details and future contact preferences

Sent by email: [email protected] [email protected]

0118 9520 500

10 August 2020

South Oxfordshire – Wallingford Draft Neighbourhood Plan – Regulation 15 Consultation

Dear Sir/Madam,

Thames Water are the statutory water supply and sewerage undertaker for the Wallingford Neighbourhood Plan area and the whole of the South Oxfordshire District and are hence a “specific consultation body” in accordance with the Town & Country Planning (Local Planning) Regulations 2012. Thames Water’s previous response on the draft Neighbourhood Plan is still relevant, but we wish to make the following comments:

Specific Comments on Water and Wastewater/Sewerage Infrastructure

Foul Flows drain to Cholsey Sewage Treatment Works. Potable water services to the area are also provided by Thames Water.

Thames Water has a duty to provide maintain and extend its networks to accommodate new development with funds for network upgrades coming from infrastructure charges https://developers.thameswater.co.uk/new-connection-charging and funds for STW upgrades coming from its strategic business plan https://corporate.thameswater.co.uk/about-us/our- strategies-and-plans/our-5-year-plan-for-2020-to-2025.

The time to deliver infrastructure shouldn’t be underestimated it can take 18 months – 3 years for local upgrades 3 – 5 years for those more strategic in nature.

The scale of any sewerage/wastewater upgrades will depend on the type, scale and location of development.

General Comments

New development should be co-ordinated with the infrastructure it demands and to take into account the capacity of existing infrastructure. Paragraph 20 of the National Planning Policy Framework (NPPF), February 2019, states: “Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for… infrastructure for waste management, water supply, wastewater…”

Paragraph 28 relates to non-strategic policies and states: “Non-strategic policies should be used by local planning authorities and communities to set out more detailed policies for specific areas, neighbourhoods or types of development. This can include allocating sites, the provision of infrastructure…”.

Registered address: Thames Water Utilities Limited, Clearwater Court, Vastern Road, Reading RG1 8DB

Company number 02366661 Thames Water Utilities Limited is part of the Thames Water Plc group. VAT registration no GB 537-4569-15 Paragraph 26 of the NPPF goes on to state: “Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary….”

The web based National Planning Practice Guidance (NPPG) includes a section on ‘water supply, wastewater and water quality’ and sets out that Local Plans should be the focus for ensuring that investment plans of water and sewerage/wastewater companies align with development needs. The introduction to this section also sets out that: “Adequate water and wastewater infrastructure is needed to support sustainable development” (Paragraph: 001, Reference ID: 34-001-20140306).

Water and Wastewater Infrastructure Delivery

The way water and wastewater infrastructure will be delivered has changed. Since the 1st April 2018 all off site water and wastewater network reinforcement works necessary as a result of new development will be delivered by the relevant statutory undertaker. Local reinforcement works will be funded by the Infrastructure Charge which is a fixed charge for water and wastewater for each new property connected. Strategic water and wastewater infrastructure requirements will be funded through water companies’ investment programmes which are based on a 5 year cycle known as the Asset Management Plan process.

It is important not to under estimate the time required to deliver necessary infrastructure. For example to understand, design, and deliver local network upgrades can take around 18 months and Sewage Treatment & Water Treatment Works upgrades can take 3-5 years. Implementing new technologies and the construction of a major treatment works extension or new treatment works extension or new treatment works could take up to 10 years.

Thames Water has limited powers under the Water Industry Act 1991 to prevent connection to its network ahead of infrastructure upgrades. In some circumstances it may be necessary to phase development in order to avoid adverse amenity impacts for existing or future users such as internal and external sewer flooding, pollution of land, and water courses and / or issues with water supply in the form of no or low water pressure. To minimise the likelihood of requiring such conditions developers are advised to contact Thames Water as early as possible to discuss their development proposals and intended delivery programme.

Comments in relation to Flood Risk and SUDS

The National Planning Practice Guidance (NPPG) states that a sequential approach should be used by local planning authorities in areas known to be at risk from forms of flooding other than from river and sea, which includes "Flooding from Sewers".

When reviewing development and flood risk it is important to recognise that water and/or sewerage infrastructure may be required to be developed in flood risk areas. By their very nature water and sewage treatment works are located close or adjacent to rivers (to abstract water for treatment and supply or to discharge treated effluent). It is likely that these existing works will need to be upgraded or extended to provide the increase in treatment capacity required to service new development. Flood risk sustainability objectives should therefore accept that water and sewerage infrastructure development may be necessary in flood risk areas. Flood risk sustainability objectives should also make reference to ‘sewer flooding’ and an acceptance that flooding can occur away from the flood plain as a result of development where off site sewerage infrastructure and capacity is not in place ahead of development.

With regard to surface water drainage it is the responsibility of the developer to make proper provision for drainage to ground, watercourses or surface water sewer. It is important to reduce the quantity of surface water entering the sewerage system in order to maximise the capacity for foul sewage to reduce the risk of sewer flooding.

Limiting the opportunity for surface water entering the foul and combined sewer networks is of critical importance to Thames Water. Thames Water have advocated an approach to SuDS that limits as far as possible the volume of and rate at which surface water enters the public sewer system. By doing this, SuDS have the potential to play an important role in helping to ensure the sewerage network has the capacity to cater for population growth and the effects of climate change.

SuDS not only help to mitigate flooding, they can also help to: improve water quality; provide opportunities for water efficiency; provide enhanced landscape and visual features; support wildlife; and provide amenity and recreational benefits.

With regard to surface water drainage, Thames Water request that the following paragraph should be included in the Neighbourhood Plan: “Surface water drainage - it is the responsibility of a developer to follow the sequential approach to the disposal of surface waters with proper provision for surface water draining to ground, water course or surface water sewers being given. The discharging of surface waters to the foul sewer can be a major contributor to sewer flooding and should therefore be avoided”.

Section 9.3 – Water and Wastewater Infrastructure

We previously requested a new policy or additional text regarding Water and Wastewater Infrastructure in the draft Neighbourhood Plan. Thames Water promotes the use of the following paragraphs within the Neighbourhood Plan in accordance with the Policy in the NPPF and the Local Plan:

“Developers need to consider the net increase in water and waste water demand to serve their developments and also any impact the development may have off site further down the network, if no/low water pressure and internal/external sewage flooding of property is to be avoided.

Thames Water encourages developers to use their free pre-planning service https://www.thameswater.co.uk/preplanning). This service can tell developers at an early stage if there will be capacity in Thames water and/or wastewater networks to serve their development, or what they will do if there is not.

The developer can then submit this communication as evidence to support a planning application and Thames can prepare to serve the new development at the point of need, helping avoid delays to housing delivery programmes.”

We hope this is of assistance. If you have any questions please do not hesitate to contact Stefania Petrosino on the above number. Yours sincerely,

Thames Water Utilities Ltd Q8. After the publicity period ends, your comments, name, postal address and email (where applicable) will be sent to an independent examiner to consider. The opportunity for further comments at this stage would only be at the specific request of the examiner. All personal data will be held securely by the council and examiner in line with the Data Protection Act 2018. Comments submitted by individuals will be published on our website alongside their name. No other contact details will be published. Comments submitted by businesses or organisations will be published in full, including contact details. Further information on how we store personal data is provided in our privacy statement.

Title

Name Tasha Hurley

Job title (if relevant) Planning Administrator

Organisation (if relevant) Savills

Organisation representing (if relevant) Thames Water

Address line 1 Hawker House

Address line 2 56 Napier Road

Address line 3

Postal town Reading

Postcode RG1 8BW

Telephone number 01189520509

Email address [email protected]