South Oxfordshire District Council by Email: Planning.Policy@Southoxon

Home , Clifton Hampden, Shillingford, Stadhampton

County Hall New Road Oxford OX1 1ND

South Oxfordshire District Council Director for Planning and Place By email: [email protected] – Susan Halliwell

26 January 2018 Copy: [email protected]

Dear Sir/Madam

Benson – Submission Neighbourhood Plan Comments to be forwarded to independent Examiner

Please find attached the County’s comments on the submitted Benson Neighbourhood Plan. We do not request a public examination on this neighbourhood plan, but if there is one, we request that we attend. We request that we are kept informed of any decisions.

Benson is one of the larger villages in South Oxfordshire. The South Oxfordshire Proposed Submission Local Plan calculates that due to the amount of completions and commitments there has been, there is no need to allocate land on the basis of achieving a target of 15% growth between 2011 and 2033 as follows (taken from p66 of Proposed Submission Local Plan):

Larger village Core Strategy Completions & Outstanding Target for + 15% growth Commitments NDP Benson 383 514 0 (+131) 0

The Neighbourhood Plan proposes to allocate land as follows: 1. NP2 – Land to the north of Littleworth Road (Site BEN1 Phase 2) – anticipates some 240 houses plus open space, allotments and part of the ‘relief road’; 2. NP3 – Land off Hale Road (Site BEN 2) – anticipates some 80 houses and part of the ‘relief road’; 3. NP4 – Land north and north east of The Sands (Sites BEN3/4) – anticipates some 240 houses and part of the ‘relief road’; 4. NP5 – Land south of St Helen’s Avenue (Site BEN7) – anticipates a burial ground on part of the site.

In respect of the above, there have been the following planning applications: 1. NP2 – BEN 1 Phase 2 – P16/S1139/O – 241 homes – Planning permission granted 18/1/18. The Phase 1 development to the south for 187 homes was permitted pursuant to P14/S0673/FUL and P15/S3293/FUL. It is understood that

this entire development of 428 houses is included in the Local Plan ‘completions and commitments’ figures. 2. NP3 – BEN 2 - P17/S3952/O – for up to 84 homes – under consideration. 3. NP4 – BEN3/4 - P17/S1964/O – for up to 240 homes – under consideration. 4. NP5 – BEN 7 – P16/S1301/O – for up to 130 homes – the appeal was dismissed on 31/8/17 and permission was refused.

Sites referred to in the Neighbourhood Plan are shown on the drawing below (page 26 of Submission Neighbourhood Plan). A Proposals Map needs to be produced.

The Proposed Submission Local Plan Second Preferred Options also contains a proposal to safeguard land for a Benson Bypass shown on the map below (page 219 of Proposed Submission Local Plan).

A recent drawing of the alignment of the Benson Bypass / Relief Road is as follows (S106 agreement for P16/S1139/O):

The County Council has provided advice to the District Council and the Neighbourhood Plan group; has provided comments at the pre-submission stage of the neighbourhood plan and on the Local Plan; and has commented in respect of applications on all three sites proposed for allocation which relate to the proposed bypass referred to hereafter as the ‘relief road’. All comments are publicly available. For information, we include extracts of our November 2017 Local Plan response at the end of this comment.

Yours sincerely

L Hughes

Lynette Hughes Senior Planning Officer Email: [email protected]

ATTACHMENT – COMMENTS FROM OXFORDSHIRE COUNTY COUNCIL BENSON SUBMITTED NEIGHBOURHOOD PLAN – JANUARY 2018

Transport

Relief Road

1. We are generally supportive of the submitted Neighbourhood Plan. We note that further detail has been supplied compared to the draft Neighbourhood Plan regarding the rationale for the proposed new relief road. The traffic flow data provided in Appendix F is also useful for assessing the impacts on Benson and the B4009 as a result of the planned developments and growth.

2. The neighbourhood plan policies are clear that the intention is that each of the three residential development sites will deliver a section of the relief road and make a contribution to the tie into the network at either end. While funding is not yet entirely clear or assured, and it is not a County Council scheme, we are content that the neighbourhood plan sets in place appropriate policies to help achieve the relief road and explains the situation in the supporting text.

3. The policies for allocating the three sites all refer to the provision of the relief road before occupation of 50% of the anticipated quantum of housing on each site. The County Council in its recent responses to P17/S3952/O and P17/S1964/O dated 19 January 2018 agrees with this approach. However, we have provided for an alternative solution as well – we are suggesting a condition that, “No more than 50% of the proposed dwellings shall be occupied until the full Edge Road is constructed and opened to traffic or a scheme at the A4074/Church Road junction is implemented to the satisfaction of the highway authority”. In reviewing the Neighbourhood Plan we would ask that the Examiner considers the most up-to-date situation with the applications for development and ensures that the allocation policies are consistent with one another.

4. A specification for the relief road is contained within the 19 January 2018 application responses. Neither the specification, nor the relief road route, is set out in the neighbourhood plan. We do not believe it is necessary to include that detail in the Neighbourhood Plan, but if the Examiner considers it necessary, we would refer to our responses on P17/S3952/O and P17/S1964/O as well as the S106 agreement for P16/S1139/O.

5. The western edge of the proposed relief road is close to the boundary of the parish and neighbourhood plan area. We are aware that a new edge road would have wider effects than just Watlington and Pyrton. We expect that the Examiner will consider whether this is already addressed through the Local Plan consultation, or whether, if recommended for referendum, residents from a wider area should be able to vote.

Centre of Benson

6. For the new relief road to be successful in diverting traffic, measures may be needed in the centre of Benson to discourage use of the existing roads and instead utilise the new alternative e.g. traffic calming. Paragraphs 12.14.7 and 12.14.10 mention the possibility of reducing speed limits along the High Street and Oxford Road to 20mph – this would need approval from the County Council as Highway Authority and be subject to statutory processes. It is noted that Appendix I sets out possible items that could receive CIL funding, such as the Parish’s proportion of CIL, in future, and this includes traffic calming measures.

Public Transport

7. Public transport is described from paragraph 12.9.1 and Policy NP10 is relevant. Benson currently has a reasonable bus service to local towns, but the future of these services is uncertain (as future commercial operations will stand or fall on usage). It is the County Council’s intention to continue to seek ‘pump-priming’ funding from developer contributions to support improved frequencies of 3 then 4 buses per hour which is expected to eventually be commercially viable once development sites on the line of route are fully built-out and occupied, generating significant numbers of additional commuters and other bus users. The County Council is content that there is no specific mention of this in the Neighbourhood Plan as it can be dealt with through Local Plan policy.

Pedestrians and Cyclists

8. Policy NP11 mentions that new cycle paths will be expected with all significant development proposals. Safe cycle access to new development sites is considered by the highway authority when reviewing and commenting on planning applications, but the provision of separate cycle paths within development sites is uncommon. While we do not object to the policy per se, it may be that the County Council would not be able to require such on-site cycle paths in accordance with Regulation 122 of the CIL regulations i.e. such that is necessary to make the development acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development.

Car parking

9. Policy NP9 states that developers will be expected to provide as a minimum the parking provisions set out in National and County Guidelines. We raised some concerns with the use of the word ‘minimum’ in our response at pre-Submission stage, but we do not consider it necessary to object to this policy. Where it would be appropriate to the overall design and layout of the development concerned, proposals which deliver car parking in excess of the minimum standards will be supported. In making an assessment, we note that a balance is required between the provision of additional parking and encouraging more car use. The Highways Authority uses

OCC/District parking standards and NPPF guidance. Each application is assessed on a case by case basis.

Education

10. Development of the scale anticipated in Benson is expected to require Benson CE Primary School to expand from its current 1 form entry to 2 form entry. The first phase of expansion, to 1.5 form entry, is already being planned. Further expansion to 2 form entry would be subject to confirmed population growth. The expansion of the school is dependent on the proposed detached playing field for the school being provided in a timely manner within the allocated site NP2 – BEN1.

11. It is likely that the scale of development proposed would leave few spare primary school places even with the school at 2 form entry size, particularly if housing is built over a short period, and therefore any significant additional housing growth above that included in this Plan may exceed the expanded school’s capacity. The Plan recognises this constraint on growth in paragraph 13.12.12.

12. For secondary education, Benson is in the designated area for Wallingford School, which has embarked upon expansion by one form of entry. Its building plans enable the school to expand by another form of entry in the longer term to meet the needs of housing development. Given the cumulative impact of housing growth across the school’s designated area, it may be that this is not sufficient, but demand for places at Wallingford School will also be affected by changes in the surrounding area, for example new schools in Didcot, which may attract some pupils who would otherwise have attended Wallingford. There could also be an impact from any new/expanded secondary education provision resulting from strategic growth at Chalgrove and Berinsfield. The county council will continue to work with local schools to ensure there are sufficient secondary school places available.

13. Paragraph 13.12.3 includes data on current school capacity and pupil numbers:

14. Updated figures are now available:

On Roll (September 2017) Benson CE Primary School 208 RAF Benson Primary School 179 Combined 387

15. As noted in paragraph 13.12.4, Benson CE Primary School is expected to expand to 1.5 form entry in the near future, and may expand further to 2 form entry in the longer term.

16. Paragraph 13.12.7 states that pupil numbers at Wallingford (secondary) School totalled 1163 in 2016:

17. Updated September 2017 figures are:

7 8 9 10 11 12 13+ Total

209 194 190 196 189 130 121 1229

18. As referred to in paragraph 13.12.4, Wallingford School has embarked upon expansion by one form of entry, and is expected to expand by a further form of entry in due course.

19. Paragraph 13.12.8 states that pupil numbers at Icknield Community College totalled 612 in 2016:

20. Updated September 2017 figures are:

7 8 9 10 11 Total

168 144 130 124 98 664

21. As referred to in paragraph 13.12.9, planning for Icknield Community College is dependent on confirmation of development proposals across a wide area.

22. If the Examiner feels it is appropriate, the updated figures could be included in the neighbourhood plan, but the County Council is not objecting on this matter per se.

23. Paragraph 13.12.12 is an accurate assessment of the limits to growth based on the primary school’s potential for expansion.

24. Paragraph13.12.17 supports the need for school expansion, but encourages the School Trustees to retain as much as possible of the existing school field as green space, particularly for informal break-time recreation. The county council would concur with the desirability of retaining green space, but notes that the extent to which this is possible will depend on the need for additional school accommodation. 7

Public Health

25. We are pleased to see that comments made at the Pre-Submission stage on the need to reduce traffic to schools and provide active travel routes to schools have been taken on board with additional references in the Plan.

Minerals and Waste

26. Site allocations NP2, 3, 4 & 5 are all underlain by deposits of sand and gravel and are within a Mineral Safeguarding Area to which policy M8 of the Oxfordshire Minerals and Waste Local Plan: Part 1 – Core Strategy applies. They are also all within “The Thames and Lower Thame Valleys area from Oxford to Cholsey” strategic resource area which is a principal location for aggregate minerals extraction in policy M3 of that Plan.

Site NP2 (BEN1)

27. This site is the subject of planning application P16/S1139/O for 241 dwellings, granted 18/1/18. The County Council originally objected to a similar application, P15/S3916/O, on grounds of mineral sterilisation but subsequently withdrew the objection when the applicant provided further information to show that the additional sterilisation of sand and gravel resources that would result from the proposed development would be relatively small and because limited weight could be given to emerging Minerals and Waste Local Plan policy on mineral safeguarding at that time. Accordingly, no such objection was made to application P16/S1139/O.

28. The proposal for site NP2 in the Benson NP appears to be very similar to that in application P16/S1139/O, including requirements for an area of green space within the western part of the site adjacent to Lady Brook and along the northern boundary of the site, as shown on Figure 11 of the Benson NP. On this basis, there are no minerals or waste policy objections to proposed site allocation NP2 (BEN1).

Site NP3 (BEN2)

29. This relatively small site is heavily constrained by existing adjacent housing to the south and north/north east and permitted housing adjacent to the south west (application no. P16/S3611/FUL), which would be added to by the further housing proposed in site NP2 to the west.

30. Any additional sterilisation of mineral resources (sand and gravel) resulting from the proposed housing development within this site would be minimal.

31. Therefore there are no minerals or waste policy objections to proposed site allocation NP3 (BEN2).

Sites NP4 (BEN3) and NP5 (BEN4)

32. The sand and gravel deposits to the north east of Benson (east of Hale Road and north of Watlington Road, B4009), which partly underlie these two sites, are of more limited extent, being towards the margin of the Thames river valley sand and gravel deposits. Large parts of site NP4 (particularly on its western and southern sides) and the south western and north eastern parts of site NP5 are constrained by existing adjoining housing. The Benson NP requires that a significant part of the area of these sites (within the northern/north eastern part of these sites) be left undeveloped as local green space, as shown on Figure 11 of the Benson NP. Taking these factors into account, the additional sterilisation of mineral resources that would result from the proposed housing development within these two sites would be relatively small.

33. On this basis, there are no minerals or waste policy objections to proposed site allocations NP4 & NP5 (BEN3 & BEN4).

Property

Site BEN10

34. Although we have not seen a Proposals Map for definitive boundaries, it appears that the allocation policy NP4 covers only sites BEN3 and BEN4 and not the adjoining site of BEN10, owned by the County Council.

35. Appendix A assesses BEN10, an area of 0.2ha, referred to as ‘Land to the north of the The Meer’ with the following comment: “This site neither contributes to nor detracts from the Benson Masterplan, though it does conform to our preferred spatial strategy for growing the village sustainably. It is not allocated for development in this Neighbourhood Plan, but is kept in reserve for 100% affordable rent / shared ownership housing to meet the needs of the local community if required over the lifetime of this Plan”.

36. The County Council sought allocation of this site as part of the policy covering the neighbouring sites. We are concerned that the assessment from Appendix A is reflected in Section 9.5 of the Neighbourhood Plan. We have not sought that it is allocated for only affordable housing, but instead for a normal mix of housing.

37. We object to the reference in Section 9.5 and seek that it is amended as follows: “A small-scale site at The Meer (BEN10) has been identified as a possible site for 100% affordable housing in future”. ‘Appendix A’ is in effect an evidence document, not an ‘appendix’ and should be changed to thus.

38. The County Council may wish to dispose of the asset or pursue a planning application on the site at some stage.

Site BEN9

39. Appendix A assesses Site BEN9, an area of 0.41ha, ‘Benson Materials Store, Land to the south of St Helen’s Ave’ with the following comment: “This site lies on the south 9

side of St Helen's Avenue. During the consultation phase for the Pre-Submission Draft of the Neighbourhood Plan, the owners, OCC, recommended that the site should be considered for housing. However, the site is small, likely to be contaminated, lies almost wholly in Flood Zone and exhibits considerable biodiversity interest. It is directly adjacent to Benson Brook, which is a chalk stream (a BAP habitat) and a key nature conservation asset for the village. EA advice is that the site would not be suitable for housing. It provides informal access to some of Benson's most important green spaces. The site could be very useful as a parking area for those visiting these green spaces and other facilities surrounding St Helen’s Avenue. The site is therefore not allocated for domestic dwellings but rather for mixed green space and parking use. This site does not conform to the Benson Masterplan or our preferred spatial strategy for growing the village sustainably and is therefore not allocated for housing in this Neighbourhood Plan. It is however allocated for mixed green space and parking use”.

40. Section 9.5 refers to BEN9 as being allocated for a green space nature area with car parking. It says “Parts of two further sites are allocated for provision of communal facilities, one for burial ground (BEN7) and one for green space nature area with car parking (BEN9 – Materials Store).”

41. We have not found a proposals map with definitive boundaries but it appears that the site is not proposed as a Local Green Space as it does not appear in Figure 9 or in Policy NP24. We have not found any other policy proposing allocation of BEN9 for green space and parking.

42. BEN9 is a brownfield site held by the County Council for future development and the County Council does not agree that it should be allocated for green space and parking. This would not be considered to be positive planning for sustainable development as a wider range of uses may be possible and therefore any such allocation would fail to meet the basic conditions for Neighbourhood Plans. We also note that green space and parking together may conflict with other neighbourhood plan policies such as NP29 relating to ecology.

43. We object to the reference in Section 9.5 and seek that it is deleted as follows: “Parts of two further sites are allocated for provision of communal facilities, one An allocation is made for burial ground (BEN7) which is a community use identified as needed in the area and one for green space nature area with car parking (BEN9 – Materials Store).” It may be that no other changes are required as the text in Section 9.5 may have been included in error as it appears not to have been followed up with a proposed allocation. As above, ‘Appendix A’ should be an evidence document, and not be considered to be part of the neighbourhood plan.

FOR INFORMATION EXTRACTS OF COUNTY RESPONSE ON SOUTH OXFORDSHIRE LOCAL PLAN NOVEMBER 2017

BENSON, STADHAMPTON AND WATLINGTON BYPASSES

Para 90 The safeguarding proposals have not been amended from that included in the Second Preferred Options. The proposals arose from Neighbourhood Plans in the case of Benson and Watlington, and from the Chalgrove Airfield developers in the case of Stadhampton. The potential need for these has been considered in the ETI Stage 2 work and our comments on this are set out later in this response. Our concerns are primarily about the effects of these on the wider strategic network.

Para 91 If the safeguarding proceeds, each area of safeguarding needs to be wide enough to enable such new routes to effectively provide for future traffic by diverting the relevant A or B road. Advice from the County Council on archaeological assessment will need to be sought, and the Stadhampton proposal is identified in an area of particular archaeological interest. A small amendment to the Watlington safeguarding map is likely to be required to reflect ongoing discussions with the site promoters. The Stadhampton safeguarding may need to be amended to better reflect what is required in the area.

Para 92 Funding for such bypasses is not being sought by the County Council. The proposed safeguarding of these bypasses appears to be related either to local issues or to the effects of the development at Chalgrove Airfield. Funding would therefore logically come from those sources if it is found that the bypass proposals are necessary and do not divert traffic to cause unacceptable negative effects on other parts of the highway network. Additional funding may also be necessary for traffic calming on those parts of the villages where the A or B road has been diverted.

EVALUATION OF TRANSPORT IMPACTS

Para 104 The Evaluation of Transport Impacts (ETI) work has been conducted too quickly and does not provide sufficient evidence for the County Council to make an informed decision on the transport impacts of the proposed allocations.

Para 105 One of the main aims of the ETI is to help identify a package of highway improvements to ensure the Local Plan contributes towards the delivery of sustainable development. This has not been achieved as the ETI work, in particular regarding mitigation, is not complete. This is clearly stated within the ETI, for example at paragraphs 4 and 5.

Para 106 Regarding Chalgrove Airfield, the transport evidence to date does not sufficiently prove how the transport infrastructure to support this site can be delivered. If infrastructure to mitigate the impacts of growth does not come forward, Oxfordshire County Council will object when a planning application is submitted.

Para 107 In particular, the delivery of proposed bypasses for Watlington, Stadhampton and Benson are extremely complex, involving a number of different development sites and landowners and will require the co-ordination of a number of different stakeholders. At this 11

point in time, it has not been satisfactorily demonstrated to the County Council that these pieces of infrastructure can be delivered. Delivery of Stadhampton bypass, in particular, is of major concern. With Watlington and Benson, although there will be delivery challenges, sites are proposed to be allocated along the alignment of the proposed bypasses in neighbourhood plans to help pay for them. This is not the case for Stadhampton. The schemes are seen as very much development specific and do not have strategic importance. The County Council will not be held liable for delivering these routes and costs associated. Given the requirement for third party land, a robust business case would be required to ensure delivery, potentially via a compulsory purchase order.

Para 108 Further work is required in relation to the Abingdon network and how this is performing. Given the proximity of Dalton Barracks and Marcham (in the Vale of White Horse) and Culham and Berinsfield (in South Oxfordshire), a cumulative impacts assessment in Abingdon needs to be conducted to inform the full impact. This work is underway but will not be available until after the Regulation 19 consultation has ended. The County Council is unable to comment meaningfully until it sees this additional evidence.

Para 109 It is recognised that OSM is an Oxfordshire wide traffic model so it is difficult for it to exactly represent conditions at a micro scale. However, it would be useful to clarify certain elements and coding within the model and to understand flow forecasts. It seems to be under or over-representing traffic flows at certain locations. These include but are not limited to:  A415 at Culham/Clifton Hampden  B4009/B480 (at Watlington)  B480 (towards Cowley)  B4015  A329  A40 (towards Headington)  New river crossing and Clifton Hampden by-pass

Para 110 Transport impacts in areas outside the ‘area of detailed modelling’ in OSM have not been fully assessed. Discussions with neighbouring authorities have taken place regarding the sharing of data but further work is needed to assess transport impacts outside the area of detailed modelling.

Para 111 There is no explanation to describe and justify how the various mitigation measures have been chosen and evaluated. Options appraisal is needed to ensure that the correct mitigation schemes have been chosen. Most mitigation has been proposed prior to meaningful assessment through ETI and promoted from the strategic site allocation at Chalgrove.

Para 112 Paragraph 5 of the introduction states that more detailed work is on-going between SODC, OCC and others to review the local impacts of proposed developments and potential mitigation measures associated with growth. We welcome the opportunity to conduct further work on mitigation measures with SODC, but are concerned about the amount of work still to be done and the timescales associated with this to support SODC’s Local Plan and Examination in Public.

Para 113 Due to the strategic nature of the ETI, the assessment of transport impacts focuses on District wide impacts and impacts along particular key corridors. The impacts on other roads e.g. through villages, are not examined in depth. This has impacts on the assessment of mitigation scenario (a) for example in the Stage 2 ETI (the removal of non- funded infrastructure) as the impacts of the removal of Culham to Didcot river crossing and Clifton Hampden bypass on surrounding villages and local routes is not examined in the report. This lack of explanation downplays the importance of unfunded mitigation that has been removed from this scenario, in particular Culham to Didcot river crossing, as it does not explore the impacts on Culham and Clifton Hampden bridges and on nearby villages such as Long Wittenham and Sutton Courtenay and A4130 from Milton Interchange to Didcot. It is these links, in part, that the infrastructure is designed to mitigate.

Para 114 In Paragraph 5.2.2, the forecast flow difference between Local Plan and Do Minimum show a slight reduction in trips along the M40 / A40 corridor in the PM peak. In this case (i.e. prior to the inclusion of any mitigation), the report states that this reduction is likely to be due to some of the traffic moving away from South Oxfordshire to other locations which may be more attractive in transport terms. This requires further explanation. The report also states that flows will increase along the B480, likely to be related to additional dwellings at Chalgrove and Watlington.

Para 115 Paragraph 6.3.2 refers to flow impacts under mitigation scenario (b1) and states that traffic flows will reduce on the A40 and increase on the B480, likely to be due to Watlington and Stadhampton bypasses. We have reservations as to the validity of this assessment which therefore warrants further investigation. The impacts of proposed growth and mitigation on the A40 and B480 need to be examined in more depth, in particular the scale of changes and the reasons for them. The County Council would not support the delivery of new transport infrastructure which would lead to traffic diverting off the M40 /A40 corridor and onto the B480 as an alternative route to and from Oxford. The B480 is a B road and passes through a number of rural villages and should not be used as a substitute for an A road. Further work to examine the impacts of proposed mitigation measures for the Chalgrove Airfield strategic site is essential, in particular to assess the impacts on other roads and settlements in the area. This needs to take place before OCC can support a strategic allocation at Chalgrove Airfield.

Para 116 Paragraph 3.2 of the ETI Stage 2 explains that the results of the model show a mode shift from bus and rail to the car which suggests that transport accessibility may need to be considered further as part of the Local Plan. This demonstrates the importance of proposed allocations being able to provide good public transport to serve the sites, in order to provide opportunities and alternatives to the private car. This is especially relevant to places such as Chalgrove Airfield which is in a rural location and with relatively poor public transport accessibility, Berinsfield which benefits from public transport serving the A4074 but is too far for most to walk from the proposed development site, and Culham which has no existing bus service (although proximity to the rail station is a benefit). The Sustainable Transport Study does look at options for improving bus services in Oxfordshire, but further work is needed to ensure that the ideas presented are deliverable and commercially sustainable.

Para 117 A further concern identified in the ETI is the alignment of the proposed Stadhampton bypass. The model shows that although such a Stadhampton bypass appears to help to reduce traffic travelling through that village, issues at Chiselhampton near the junction of the B480 and B4015 are not addressed. 13

Para 118 It may be that additional or alternative proposals to mitigate transport effects from the proposed allocations are required. Some work was done within the ETI, for example to explore the need for a Nuneham Courtenay bypass. Although there are capacity issues identified on the A4074, a bypass at Nuneham Courtenay is shown to do little other than move the capacity issues towards Oxford, and therefore is correctly not proposed.

Para 119 It has been suggested by the Homes and Communities Agency that Hollandtide Lane will be upgraded as part of the transport mitigation for Chalgrove Airfield. Improvements could help to redirect traffic travelling between Benson and Chalgrove Airfield away from other roads which would impact on villages. However, at this stage it is unclear what improvements are suggested, there is no safeguarding for widening in the Local Plan and the suggestion has not been modelled.

Para 120 The impacts of identified new road proposals not being delivered before development commences is not examined. At the present time the Didcot-Culham River Crossing is not funded, although a bid for government funding was made in September 2017. It is assessed that the River Crossing is needed for development on the land adjoining the Culham Science Centre, and to some extent for development at Berinsfield. It is also needed to some extent for already committed development in Didcot.

Para 121 There are parts of the highways network which are shown to be over capacity in the Local Plan scenarios but no mitigation has been tested or proposed as part of the ETI, e.g. A415, A40 on the approaches to Green Road roundabout, A4074 near Berinsfield/ Shillingford / Benson / Crowmarsh; Berinsfield (Fane Drive); A418 Aylebury Road in Thame; parts of the A4130 in Didcot. The reasons for not seeking to mitigate impacts on the transport network in these areas needs to be provided; alternatively additional transport mitigation needs to be investigated to address these issues.

Para 122 The general approach to highway network performance may not provide the best measure of localised junctions. It is at these key nodes where capacity issues exist. Further and more detailed work will need to be conducted as development sites progress. This should include appropriate modelling packages with robust traffic flow data including queue length surveys.