South Oxfordshire District Council by Email: Planning.Policy@Southoxon
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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). 2 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] 3 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. 4 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 5 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.