East Hagbourne Neighbourhood Development Plan 2018 to 2033 - Consultation

Representations on behalf of Nurton Developments, December 2018 2 Contents and Introduction

CONTENTS 1.0 SECTION 1 - INTRODUCTION

SECTTION 1 - INTRODUCTION 1.1 These representations are prepared jointly 1.6 The EHNDP must meet the ‘basic conditions’ and by Chave Planning and Urban Wilderness, on other matters set out in paragraph 8 of Schedule SECTION 2 - LANDSCAPE CONSIDERATIONS behalf of Nurton Developments, in response 4B to the Town and Country Planning Act 1990 (as to consultation on the East Hagbourne amended). The basic conditions (as far as they are SECTION 3- GREEN BUFFERS AROUND EAST HAGBOURNE Neighbourhood Development Plan (EHNDP) relevant to neighbourhood plans) are as follows: Submission Version, 17th September 2018. SECTION 4 - POLICY VC1a a. having regard to national policies and advice 1.2 Nurton Developments is a privately owned contained in guidance issued by the Secretary of SECTION 5 - POLICY VC2 property development and trading company State it is appropriate to make the neighbourhood specialising in strategic land promotion. Nurton plan. SECTION 6 - POLICY H3 Developments has an interest in land in the parish and Neighbourhood Plan area of East Hagbourne, d. the making of the neighbourhood plan SECTION 7 - SUMMARY located adjacent to Didcot, as shown on Figure 1. contributes to the achievement of sustainable development. 1.3 Chave Planning is a town planning consultancy and these representations are prepared by e. the making of the neighbourhood plan is in Caroline Chave BA(Hons) DipTP MRTPI, who has general conformity with the strategic policies 19 years’ experience in development control and contained in the development plan for the area of plan-making. the authority (or any part of that area).

1.4 Urban Wilderness is a landscape architecture, f. the making of the neighbourhood plan does masterplanning and urban design consultancy and not breach, and is otherwise compatible with, EU these representations are prepared by Nathan obligations. Edwards BA(Hons) DipLA CMLI, who has 18 years’ experience in landscape assessment, design and g. prescribed conditions are met in relation to the masterplanning. plan and prescribed matters have been complied with in connection with the proposal for the 1.5 This document will be structured firstly with an neighbourhood plan. assessment of the landscape characteristics of land between Didcot and East Hagbourne, with 1.7 These representations will have regard to the regard to the evidence base behind the EHNDP. basic conditions and, in particular, will consider Representations will then be set out in response whether the Neighbourhood Plan is compliant to policies in the EHNDP. with national policies and the development plan and whether it contributes to the achievement of sustainable development. 3 KEY Site Boundary

Distance from centre of application site FIGURE 1: Nurton Developments Land Interests

1.8 It is noted that the Neighbourhood Plan has been published for consultation prior to the adoption of the emerging Local Plan for South Oxfordshire. We consider it premature for the Neighbourhood Plan to determine the provision of land for housing and the protection of large areas of land against development in the parish in advance of key decisions regarding the location of sustainable development in the South Oxfordshire Local Plan. We consider that the Neighbourhood Plan process should be halted until the South Oxfordshire Local Plan has determined strategic planning issues and been found sound following examination.

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2km 209-P-0XX 25 Jan 17 Shortlands Farm Location Plan 4 Landscape Considerations

2.0 SECTION 2

The East Hagbourne Village Character Assessment and Landscape Study (2018) - EHVCALS

2.1 The character of land identified as Lower End 2.3 Whilst a methodology is included within the 2.5 Moreover, whilst it is common practice to make Field (Area VF08) within the East Hagbourne EHVCALS, (Section 2, page 2) it does not provide reference to current and preceding landscape Village Character Assessment and Landscape the reader with any assessment criteria nor studies, and to draw from their findings to support Study (2017), comprises of a “...large area of provide a transparent summary as to how more detailed analysis, the EHVCALS does not open farmland, which although managed as a important judgments have been made. This is draw any apparent conclusions from National number of separate fields, retains no internal particularly relevant given the study was ‘enriched’ Character Areas or from the South Oxfordshire hedgerow boundaries.” The EHVCALS goes on to with text provided through workshop consultation Landscape Character Assessment (2003). It is describe the area’s landform as having “...a low with local residents. Whilst the methodology certainly unclear as to whether these studies have crest running east to west through the centre makes reference to Landscape and Visual Impact been used to help define identified Landscape of this parcel, falling gently towards the existing Assessment guidance by the Landscape Institute, Character Types, (refer to Figure 2). urban edge to the north and in a similar manner the link provided directs the reader to a generic towards the Alluvial Lowlands to the south, technical resources page hosted by the Landscape 2.6 Following description of a baseline the EHVCALS where it is bordered by the Great Mead track.” Institute, and not to specific evaluation criteria. goes on to score Land Cover Parcels based on The landscape is described as “...a very open Nor does the assessment adopt any of the their historical significance and their natural landscape with distant views of the urban edge to guidance principles or procedures for assessing significance, i.e their contribution towards the the north and west and across adjoining farmland landscape and visual impacts set out in the GLVIA3 historic environment and their contribution south and east to the Chilterns.” (references from guidance. towards wildlife and habitat. Each is scored from para 1, page 37, EHVCALS) ‘Very Low’ significance to ‘Very High’ significance. 2.4 The EHVCALS divides the parish up into Landscape In the case of Lower End Field the EHVCALS 2.2 The scope and purpose of the EHVCALS was to Types, (defined by common characteristics scores parcel VF08 as being ‘Highly’ significant undertake both heritage and landscape studies for including land use and landscape features) and to the historic environment and of ‘Moderate’ the parish as a whole, and through their combined then into distinct Land Cover Parcels, (defined by significance to the natural environment. assessment to help steer the neighbourhood their physical extents such as roads, hedgerows, planning process in terms of landscape ditches etc). Both are then characterised into 2.7 Without the benefit of a defined set of assessment conservation and protection. The EHVCALS 11 distinct Local Character Areas (LCAs). The criteria it is difficult to establish how these forms part of the evidence base supporting the EHVCALS does not fully explain how these varying conclusions have been drawn. In both cases we Submission Version of the Neighbourhood Plan levels of characterisation have been developed or contend that this assessment appears somewhat and in particular underpins decisions directing indeed how their boundaries have been drawn. overstated. development towards those areas considered to be the least sensitive to identified development pressure. 5

FIGURE 2: National and Regional Landscape Character Areas

2.8 With regard to historic significance an assessment of ‘High’ significance establishes that an area retains, “...a strong survival of pre-1920 historic character, including historic buildings, boundaries routeways and earthworks including ridge and furrow, intermixed with higher degree of later buildings or changes to the landscape.” (Table 3, Page 47).

2.9 Given that the EHVCALS acknowledges that the area has no heritage features or assets (table on page 71) and that “... intensive ploughing has removed evidence of ridge and furrow…” and that the Land Cover Parcel “...retains no internal hedgerow boundaries.” (para 1 page 37) it is difficult to reconcile the Land Cover Parcel description with an assessment of ‘High’ significance.

2.10 It is our view that Lower End Field falls somewhere between a ‘Low’ and a ‘Moderate’ historic significance, in that it is dominated by post-1920 change. It has been intensively farmed and its northern and western boundaries exert an urbanising influence over the landscape with views of post-war housing. For an area to be of ‘Moderate’ significance it must have retained some earlier features such as routeways, field boundaries, ridge and furrow etc.; some of which remain but the majority of which have now been lost. 6

2.11 Similarly with regards to Natural significance, 2.14 This description is consistent with the Landscape 2.20 To conclude the EHVCALS notes within the table Lower End Field is identified as being of ‘Moderate’ Management Issues identified on page 49 of on page 71, that “Given the open, large scale significance. This level of significance establishes the South Oxfordshire LCA which states that nature of the adjoining agricultural landscape that areas “...which have experienced removal of “Most of the remaining farmed landscape of the and the location of the site on a low ridge, there boundaries and other changes but which retain character area, while still rural and attractive, is is no scope for any new development within habitats within them (eg survival of orchards, showing some signs of decline in condition and this land cover parcel without causing major floristic diversity on ridge and furrow) and historic quality. Principally this is the result of a general visual impact on the open rural character of plots and boundaries.” (Table 4, Page 48), are of weakening of landscape structure through this productive arable landscape in relationship Moderate significance. As noted above Lower End intensive arable farming, creating an open and to the medieval village.” It is our view that this Field has been intensively farmed and managed denuded character.” statement is subjective and unjustified. Firstly the for many years. study does not pertain to assess visual impact and 2.17 Within Part 5, the EHVCALS provides a judgement cannot therefore do so robustly without sufficient 2.12 The only habitats of any note are the narrow with respect to Local Gap Designation, (Figure evidence. Secondly each development proposal field margins either side of the Public Right 39), and the identification of key views (Table 9). should be judged on its own merits, including its of Way (north to south through the area) and physical extents, screening and integration within the landscape in the vicinity of the Great Mead 2.18 The assessment provides little discussion with its surrounds. A point acknowledged by paragraph bridleway which borders the Land Cover Parcel to respect to justification of areas to be designated 3 of page 46 which states that “It must be the south. as ‘Local Gap’ or explanation as to their extents. emphasised that the scoring is not a ‘once and for Similarly the assessment identifies key views but all’ judgement, because new evidence may arise, 2.13 It is our contention that habitats within area provides little explanation as to their significance. perceptions change and also the effect of any VF08 are heavily restricted, fragmented and particular scenario will change depending upon at best limited to the margins of the area. The 2.19 EHVCALS Figure 40: Key Views (page 59) identifies its scale and design, integration with surrounding intensive management of the area has resulted a number of key views. The study does not areas etc.” in a poor biodiversity. The definition provided however go on to describe these views or provide for Low natural significance, namely “Areas images to illustrate their significance. With regard 2.21 Whilst a statement of landscape capacity, i.e. a which have been changed (eg loss of orchards, to Lower End Field (view 10), our analysis identifies landscape’s ability to accommodate change being housing development), but which have potential that views include notable urban influences, considered high, medium or low is justified, if for management to benefit wildlife (eg gardens, including homes along New Road and views to supported by robust evidence, overall it is the place ponds).” (Table 4, Page 48), would appear more the Didcot power station. In addition views south of development control policy and development fitting for parcel VF08, i.e. a landscape which and east are partially screened towards the wider allocations to evaluate the appropriateness of has been changed and which clearly offers the countryside due to intervening vegetation. One's development. potential for enhancement. sense of a gap between East Hagbourne and Didcot is local to the viewer by merit of a break in development, and is not reliant on views over the wider area. KEY

Site Boundary

Distance from centre of application site

7

Landscape Appraisal FIGURE 3: 2.22 Our own assessment of the landscape to the 2.25 We acknowledge that there is a degree of Sense of Separation north east of East Hagbourne concurs with the perceptual value attached to the area as a South Oxfordshire LCA, in that Lower End Field consequence of the perceived gap between East forms part of a broader landscape with common Hagbourne and Didcot, glimpsed views towards characteristics. The landscape character accords the AONB and due to the area’s limited use by with the description of the Flat Open Farmland walkers along the PRoWs which cross the area. LCA, and features such as pylons and the existing Besides these attributes the area has limited urban edge of East Hagbourne and Didcot exert recreation value and no other cultural associations an urbanising influence across the area. have been identified. Should open space be retained between points A and B on Figure 3, it is 2.23 Lower End Field is not covered by any formal our view that a gap between East Hagbourne and A landscape designation such as an AONB or Didcot would maintain one's sense of separation National Park, albeit The North Wessex Downs between settlements. AONB lies adjacent the area to the east. Intervisibility between Lower End Field and the 2.26 To conclude, the emphasis placed on Land Cover AONB is partially screened by a row of mature Parcel VF08 should in our view not focus on trees, aligned north to south just within the area’s preservation, i.e. maintaining the status quo, but eastern boundary. The AONB is further screened instead should focus on opportunities that deliver from New Road by existing tree planting and landscape enhancement. The South Oxfordshire fencing. Some distant views are possible; where LCA notes that the area needs “Intervention to these are available they do provide a sense of repair or, more typically, to restore diversity to the connection to the wider landscape. Key views are landscape and to reintroduce a stronger pattern B considered further in relation to Policy VC2. and structure of field boundaries, belts of trees B and blocks of woodland…”. Some development 2.24 Given this combination of factors Land Cover could be realised within this land parcel whilst still Parcel VF08 is not considered to be particularly maintaining the physical and visual separation of distinctive, rare or unspoilt. Moreover, contrary the two settlements. to the assertion of the EHVCALS, the Land Cover Parcel does not, in our professional judgement, significantly contribute to the historical or natural character of East Hagbourne, scoring between Moderate and Low at best. The area has limited conservation interest and there is potential for 1km significant enhancement through new Green Point A - View from gap in boundary with new Road Infrastructure provision. Points B - Great Mead Bridleway and beyond to the south and south east over open Countryside.

2km 209-P-0XX 25 Jan 17 Shortlands Farm Location Plan 8 Green Buffers

3.0 SECTION 3

3.1 Although not a policy, there is a map and 3.3 Section 10.2.4 of the GTDP states that the GTDP 3.6 The EHGBA identifies 11 landscape character supporting text concerning ‘Green Buffers around will be treated by the Council as a non-statutory areas which collectively form a ‘green buffer’ to East Hagbourne’ on pages 24 and 25 of the EHNDP. planning document. Given this status and the East Hagbourne. These areas are defined via “...a It refers to the Didcot Garden Town Delivery Plan outstanding objections to the document, Nurton distinct and recognisable pattern of elements, (the GTDP) being ‘adopted’ in October 2017 and Developments consider that the GTDP should characteristics, in the landscape that make one having ‘established’ the principle of Green Buffers. carry very limited weight as an evidence base different from another, rather than better or The EHNDP would appear to give significant document in the making of the EHNDP. The GTDP worse.” (page 3). weight to this document, which has no statutory does not have the evidential support of a DPD and status as a Development Plan document. Nurton it should not gain status by being referred to in 3.7 The EHGBA identifies Lower End Fields as Developments has made strong objections to the the EHNDP. The plan (Fig 4) and text referring to Character Area 1, that being a swathe of land ‘Green Buffer’ being identified in the GTDP and the GTDP (the last 3 paragraphs on page 24 and between Didcot and East Hagbourne, which spans these objections are as yet unresolved. the first paragraph on page 25) should therefore a number of fields, east to west (see Figure 4). be deleted from the EHNDP. The only purpose of The identification of this area as a character area 3.2 Section 1.1.7 of the GTDP confirms that Garden this text is to provide some background to the would suggest that the area in question has a Town policy will be brought forward in a proposed ‘Local Green Gaps’ in Policies VC1a-d common and ‘recognisable pattern of elements Development Plan Document (DPD). Nurton and, as will be explained in response to Policy and characteristics’. THE EHGBA goes on to Developments considers that a DPD is the only VC1a below, the designation of such ‘Local Green assess each area’s sensitivity, landscape value and appropriate document in which land can be Gaps’ is not justified. capacity to accommodate change. identified for special conservation (i.e. a green gap) and policies to be made for that area, in Appraisal of the East Hagbourne, Green Buffer accordance with Regulations 5 and 6 of the Assessment. 3.8 It is our contention that, whilst the fields that Town and Country Planning (Local Planning) comprise Lower End Fields share common (England) Regulations 2012. Therefore Nurton 3.4 The EHNDP also refers to The East Hagbourne, landscape characteristics, and indeed form part Developments intends to engage fully with the Green Buffer Assessment (EHGBA), produced by of a much wider landscape character area to consultation and examination process for the Novell Tullett (July 2018), as forming a key part of the east, as referenced in the South Oxfordshire Garden Town DPD in due course. The Garden Town its evidence towards the identification of a green Landscape Character Assessment, an assessment DPD has yet to be published for consultation, let buffer zone around East Hagbourne. of sensitivity, landscape value and capacity needs alone been subject to the rigorous examination to consider variation across each character area. requirements of a DPD. 3.5 The Methodology for this report refers to Despite common characteristics, some character guidance set out in the Landscape Character areas, such as Lower End Fields, do not have a Assessment Guidance for England and Scotland uniform character or capacity to accommodate (2002), reaffirmed by Natural England’s 2014 ‘An change. To assess them uniformly can overstate or Approach to Landscape Character Assessment’. understate their ability to accommodate change, either wholly or in part. 9

FIGURE 4: Extract from East Hagbourne Green Buffer Assessment (page 15)

3.9 With respect to Lower End Fields, the landscape is broadly enclosed to the west with filtered views to the south east, towards the wider landscape. This area includes notable urban edge characteristics. In contrast land to the east is open and expansive in nature, with wide ranging views and a more rural character. A prominent line of mature trees runs north to south dividing these two areas. Despite a similar landform and scale, this treed boundary forms a distinct boundary between a landscape with some capacity to accommodate change and another with little capacity. One area, to the west, being partially enclosed and influenced by the urban edge, and the other open and influenced by the wider rural landscape.

3.11 A further difference of note concerns the fact that land to the west of the Lower End Fields area is not designated for its beauty, whilst land to the east falls within the North Wessex Downs Area of Outstanding Natural Beauty (AONB). As a consequence of the value attached to the AONB, the EHGBA confers the same level of value to the whole of the Lower End Fields character area, despite the lack of a physical and visual inter- relationship of this designation with land to the west.

3.12 The Landscape Capacity Assessment for Sites on the Edge of Didcot, Henley, Thame and Wallingford in South Oxfordshire (Sept 2017), by Kirkham Landscape Planning Ltd / Terra Firma for South Oxfordshire District Council, provides a robust assessment of the site and clearly identifies and differentiates between these two areas, as illustrated on Figure 5). 10

TABLE 1: Comparative Summary Between EHGBA and Landscape Capacity Assessment for Sites on the Edge of Didcot, Henley, Thame and Wallingford 3.13 It is our view that, by grouping land to the west EHGBA The Landscape Capacity The Landscape Capacity together with land to the east, a greater level of Lower End Fields Assessment for Sites on Assessment for Sites on sensitivity and a reduced landscape capacity is (Tables 1,2 and 3) the Edge of Didcot, Henley, the Edge of Didcot, Henley, conferred upon the whole. Indeed the EHGBA Thame and Wallingford in Thame and Wallingford in assesses Lower End Fields as being of negligible South Oxfordshire. South Oxfordshire capacity. In contrast the Landscape Capacity Assessment for Sites on the Edge of Didcot, Area DID1a (pages 48-49) Area DID1b (pages 52- 53) Henley, Thame and Wallingford, clearly identifies that land to the west (parcel DID1a) is considered to be of medium value, medium to low sensitivity Landscape Sensitivity Major Medium / Low Medium / Low and as such of medium landscape capacity. Land Landscape Value Substantial Medium Medium / High to the east (DID1b), where the landscape is more Landscape Capacity Negligible Medium Low open and inherently interwoven with the AONB boundary, is considered to be more akin with the EHGBA. DID1b is considered to be of medium to 3.16 It is clear from the table above that the EHGBA 3.18 Fundamentally with respect to the justification for high value, and with a low landscape capacity. assessment for Lower End Fields aligns with area the provision of green buffers, It is unclear within DID1b in The Landscape Capacity Assessment the assessment how an area's landscape capacity 3.14 In our opinion the EHGBA underplays urban for Sites on the Edge of Didcot, Henley, Thame for change translates into the need for a green influences to the west, noting that “Despite the and Wallingford in South Oxfordshire. DID1a in buffer. Indeed one would assume that if an area urban boundaries it largely remains tranquil in contrast is at odds with the EHGBA assessment. has been identified as having a high sensitivity character.” (page 16). In contrast The Landscape and low capacity for change that the presumption Capacity Assessment notes that that “Tranquillity 3.17 As previously noted, an assessment of sensitivity, in favour of sustainable development, running is affected by proximity to roads and views of value and capacity should allow for variation as a ‘golden thread’ through the NPPF, would be pylons and power station”. (page 48) across character areas and in doing so recognises outweighed by potential environmental harm, and that landscape features can combine at a local as such existing local plan policy would provide 3.15 With reference to Tables 1, 2 and 3 within the level to reduce sensitivity and increase an area's sufficient development control. An additional EHGBA, the table below provides a comparative capacity for change. level of protection would, in our opinion, seem summary between the EHGBA and The Landscape unnecessary. This is particularly true of land to the Capacity Assessment for Sites on the Edge of south and east of East Hagbourne where buffers Didcot, Henley, Thame and Wallingford in South are identified extending into open countryside. Oxfordshire. It is unclear as to what these areas are seeking to buffer East Hagbourne against? Areas of land such as parcels 9 and 10, which form clear gaps between East Hagbourne and Didcot, could arguably require a buffer to prevent coalescence. It is unclear then why parcel 9, for example, has been identified as being capable of accomodating a small amount of development? (page 20). 11

FIGURE 5: Extract from South Oxfordshire District Council Landscape Capacity Assessment (Sep 2017) Evidence Base

3.19 A fundamental precept of the GLVIA3 guidance concerns professional judgement and the need for transparency and justification. In our opinion, and further to the discussion provided above in relation to the The East Hagbourne Village Character Assessment and Landscape Study (2018), this assessment lacks justification and should not therefore be relied upon as evidence to support Neighbourhood Development Plan Policy.

3.20 Similarly for the reasons stated above we believe that the East Hagbourne Green Buffer Assessment is flawed in its presentation of the Lower End Fields Character Area. Whilst this assessment provides consideration of the landscape capacity of the area around East Hagbourne, it is unclear how this assessment concludes that Green Buffers are required or indeed justified. 12

Policy VC1a FIGURE 6: Map Extract - Local Gap for Lower End Field - EHNDP page 26, Fig 5. 4.0 SECTION 4

Policy VC1a – Lower End Field Local Green Gap

4.1 This policy identifies a ‘Local Green Gap’ of some 23.15ha and says that any proposals for development in this gap should not, either individually or cumulatively, diminish the remaining gap between East Hagbourne and Didcot and should preserve the open and tranquil character of the landscape and its views.

4.2 The premise of this policy seems to be to establish a highly protected ‘no development zone’ over a large area of countryside, similar to a Local Green Space designation but under a different name. This premise is not supported by national planning policy. The Framework recognises the intrinsic character and beauty of the countryside (paragraph 170). It regards the construction of new buildings in the Green Belt as inappropriate (paragraph 145) and it supports the designation of Local Green Space (paragraph 99). It says that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes (paragraph 170) and that great weight should be given to conserving landscape and scenic beauty in certain designated areas (paragraph 172). This provides a framework for the protection of the countryside and takes a balanced view of the roles of the countryside in the context of achieving sustainable development.

4.3 The designation of a Local Green Gap is not 13

consistent with this framework of protection and it the emerging Local Plan continues to provide how the existing Development Plan policies appears that the EHNDP is attempting to effect the landscape protection. Policy ENV1 of the emerging provide an appropriate basis for protecting protection that a Local Green Space designation Local Plan (Publication Version, October 2017) says the landscape setting of settlements around would provide, but without being subject to the that development will only be permitted where Didcot. There is no need to apply an onerous rigorous policy requirements as set out in paragraph it protects or enhances the attractive landscape landscape designation in the Neighbourhood Plan 100 of the Framework. setting of settlements. This would continue the because the intrinsic character and beauty of appropriate and balanced protection of the the countryside is already recognised in planning 4.4 Outside the Green Belt, the blanket protection landscape. policy, and a degree of separation between East of large areas of countryside from inappropriate Hagbourne and Didcot will always be a material development does not feature in this national 4.7 The supporting text to Policy VC1a (page 26- planning consideration. Therefore, the additional framework. Indeed the Planning Practice Guidance 27) also refers to an appeal decision (APP/ protection proposed in the Neighbourhood Plan is says at Paragraph: 015 Reference ID: 37-015- Q3115/W/16/3153639) where planning permission not justified. 20140306, in relation to Local Green Space, that was refused and an appeal was dismissed in relation blanket designation of open countryside adjacent to 170 dwellings on a parcel of land forming part 4.10 The landscape setting of settlements around to settlements will not be appropriate and, in of the proposed Lower End Field Local Green Gap. Didcot is a wider issue that could be appropriately particular, designation should not be proposed as The conclusions of an appeal in relation to part considered in the Didcot Garden Town a ‘back door’ way to try to achieve what would of the proposed Local Green Gap should not be Development Plan Document or at district level amount to a new area of Green Belt by another extrapolated to apply to the whole of it. The Appeal in the emerging Local Plan. The Garden Town name. Policy VC1a is therefore in conflict with the Inspector only considered evidence and drew Principles set out in Appendix 6 to the emerging Framework in proposing this onerous protection. conclusions in relation to the site of that appeal, Local Plan (Publication Version, October 2017) not the whole of the proposed Local Green Gap, or include that the Garden Town will establish 4.5 The supporting text to Policy VC1a (page 24 of the indeed the Lower End Field. a confident and unique identity, becoming EHNDP) refers to various policies in the adopted a destination in itself that is distinctive from development plan. It is considered that these 4.8 In any case, the dismissal of the appeal was as a surrounding towns and villages whilst respecting policies afford appropriately balanced protection result of a balancing of considerations in terms and protecting their rural character and setting. over the countryside and the landscape setting of of the Presumption in Favour of Sustainable settlements, in accordance with the Framework. Development. The context for plan making is The additional ‘preservation’ of a green gap quite different to decision making. The context for proposed in Policy VC1a goes well beyond this and decisions to be made in terms of land use planning there is no basis in the development plan for such a in the Neighbourhood Plan is not the same. level of protection to be created. The considerations at play now are whether the proposed designation of a large area of countryside as a Local Green Gap would firstly comply with national policy and the development plan, and secondly would contribute towards sustainable development, rather than whether the adverse impacts of a development would significantly and 4.6 As recognised in the supporting text to Policy VC1a, demonstrably outweigh the benefits.

4.9 The reference to the appeal decision also highlights 14

4.11 It is intended that the Garden Town is to be 4.13 Policy STRAT1 of the Regulation 19 Publication 4.15 In conclusion, we consider that Policy VC1a should enshrined in district-level planning policy which draft Local Plan sets out the overall strategy for be deleted. is intended to establish green buffers to the development in South Oxfordshire and the main surrounding ‘necklace of villages’ (page 257, focus for major new development is the Science Didcot Garden Town Delivery Plan, October 2017). Vale, including Didcot Garden Town and Culham, This will look comprehensively at maintaining the so that this area can play an enhanced role in separate and distinct identities of all the villages providing homes, jobs and services with improved surrounding Didcot. Applying an additional and transport connectivity. Therefore the resolution pre-emptive level of protection in the EHNP could of housing supply issues following independent increase development pressure on adjoining examination of the Local Plan may require further areas and unduly constrains the making of the housing allocations to be made and Didcot Local Plan. should be a key focus for this. The imposition of a Local Green Gap designation would preempt 4.12 The local planning of sustainable development such decisions by ruling out development of any is still being undertaken by South Oxfordshire part of the area designated as a Local Green Gap District Council (SODC), with the emerging Local and, as such, would stymie the local planning of Plan yet to be submitted for examination. There sustainable development. are some major objections outstanding to the Local Plan from the County Council and other 4.13 In addition to the above it is unclear as to how Housing Market Area authorities in terms of the extents of the area identified on Figure 5 accommodating Oxford’s overspill under the have been chosen / drawn. Neither the East Duty to Cooperate and infrastructure provision. Hagbourne Village Character Assessment and Major deliverability issues have been identified in Landscape Study, or the East Hagbourne Green relation to a site allocation of 3,000 homes and Buffer Assessment, provide a justification for the 5ha of employment at Chalgrove Airfield, such location, scale or extents of this Local Green Gap that SODC now intends to make alternative or policy designation. reserve allocations to ensure that the housing requirement is met. Therefore the district-level 4.14 Given the scale of the gap afforded by the picture is far from clear in terms of the local dismantled rail line that exists between East planning of sustainable development and the Hagbourne and Didcot to the west of New Road, investment in homes and jobs. a gap of significantly smaller proportions could equally be considered to provide an appropriate Local Green Gap. Similarly the extents of a gap could equally be considered to extend broadly north to south along the existing extents of East Hagbourne as opposed to extending eastwards across Lower End Field. The scale and extent of the gap identified would appear to have been drawn arbitrarily. 15

Policy VC2 FIGURE 7: Map Extract - Key Views - EHNDP page 30, Fig 6. 5.0 SECTION 5

Policy VC2 – Conserving and Enhancing Important Views

5.1 Policy VC2 states that “Views within the village, to and from the village, and of the wider landscape A B including views towards the Chilterns and North Wessex Downs AONBs, should be protected wherever possible.” It goes on to say that “New development should avoid significant harm to the C views listed in Table 9 of the Character Assessment and shown in Figure 6…” (as repeated below).

5.2 The views relating to Lower Field (view 10), are described in Table 9 of the EHVCALS as follows; D

“Views across Lower End Field. Long distance views from New Road and FP197/24 towards the Chilterns and North Wessex Downs AONBs provide a strong sense of the open farmed landscape that still separates East Hagbourne from Didcot. Views from the south over open fields on a low ridge that soften the view towards the adjoining town.”

5.3 Table 5, relating to sensitivity of historical character, goes on to identify view 10 as being of ‘Very High Visual Significance’.

5.4 It is firstly unclear as to how the specific views illustrated on Figure 6 of the EHNDP have been selected, and secondly how significant harm to a view will be considered.

Letters in Red are our addition 16

5.5 The supporting text to Policy VC2 notes that key 5.8 Moreover there is little support in national policy views are considered important as they form a with regard to the designation of important views notable feature of the village surrounds, they are to afford protection of land against development. highly valued and they provide a soft transition The Framework is largely silent on the designation from built environment to the surrounding of important views. The only notable exception countryside. appears within text relating to Green Belt, albeit in this context visual amenity is related to the 5.6 It is reasonable to identify views towards key opportunity afforded by Green Belt to improve landmarks such as church towers, broader areas visual amenity. (Para 141). of historic significance such as the East Hagbourne Conservation Area or towards monuments or 5.9 Greater emphasis is provided in the National other heritage assets considered to be locally Planning Practice Guidance (NPPG) which states important. It is also reasonable to identify views that: towards the AONB as important given that AONBs are designated for their scenic beauty. “When thinking about new development the Views over farmland, whilst attractive, are more site’s land form should be taken into account. commonplace and in our view do not constitute Natural features and local heritage resources can ‘Key Views’. help give shape to a development and integrate it into the wider area, reinforce and sustain local 5.7 With regards to View 10, across Lower End Field, distinctiveness, reduce its impact on nature and views from the north-west and from the south- contribute to a sense of place. Views into and out east towards the AONB (further to the south of larger sites should also be carefully considered and south-east) accord with this definition of from the start of the design process.” (NPPG importance and should therefore be given further Paragraph: 007 Reference ID: 26-007-20140306) consideration. Views from the north-east and from the south, looking north and west respectively, 5.10 In this context it is our view that the wording of do not take in any notable features of natural or Policy VC1b should be changed thus: historical significance. These views instead take in the existing hard urban edge of East Hagbourne ‘Views within the village, to and from the village, along New Road and the vegetated extents of and of the wider landscape, including views Didcot. These views do not therefore appear to towards the North Wessex Downs AONB, should be important in this context and in our view are be retained and respected wherever possible. therefore unjustified. New development should be carefully designed to maintain important views wherever possible.’ 17

Figure 8: View 10 - North East of Lower End Field

5.11 With specific regard to key view 10 the above image is Historical Significance - Low (besides the line of the representative of the view available to recreational users PRoW heading south there are very few features of and a very small number of properties along St.Hildas, identifiable historical significance that contribute to the St. Hughs and Cromwell Drive respectively. Some long character of East Hagbourne). distance views are available to the south and south east including higher ground and the AONB. Views east and Natural Significance - Low (besides vegetation around south open up as one moves towards the southern end the periphery of Lower End Field there are very few of the PRoW, however from this viewpoint wider views habitat features that contribute to the character of East eastwards towards the AONB are partially screened by Hagbourne). existing mature trees. The landform, existing vegetation and urban edge limit any middle distance views. Views - Important views towards the wider landscape are possible to the South. Views East are partially 5.12 Summary Assessment of this view's importance based screened, views West and North whilst looking over on the EHVCALS : countryside are neither rare, unspoilt nor unique. 18

Figure 9: Trees partially screening views to the east towards the AONB 19

Figure 10: View 10 - South and South East of Lower End Field

5.13 This image is representative of views north from the 5.15 Summary Assessment of this view's importance Great Mead bridleway which forms the southern based on the EHVCALS : boundary of Lower End Field. The visual envelope contains the majority of Lower End Field and very Historical Significance - Low (besides the line of the little else. The urban edge of properties along New PRoW heading north there are very few features of Road enclose the land parcel and, combined with the identifiable historical significance that contribute to boundary vegetation and landform, restrict any long the character of East Hagbourne). distance views. From this location no sense of a gap between East Hagbourne and Didcot exists as views Natural Significance - Low (besides vegetation of development along New Road and Didcot appear around the periphery of Lower End Field there are continuous. Key features within the visual envelope very few habitat features that contribute to the include Didcot Power Station and a line of electrical character of East Hagbourne). pylons (out of shot to the east). Views - Important views towards the wider landscape 5.14 Wider views due east and south towards the AONB are possible to the south and east. Views north and are possible from this point. west whilst looking over countryside are neither rare, unspoilt nor unique 20

Figure 8: View 11 - North West of Lower End Field

5.16 Taken from New Road this image is representative 5.18 Summary Assessment of this view's importance Views - Important views towards the wider of the view experienced by road and footpath users based on the EHVCALS : landscape are possible to the south-east. Views east and a small number of properties which front Lower are partially screened. End Field. The visual envelope is partially enclosed Historical Significance - Low (There are very few by existing boundary planting and a fence along the features of identifiable historical significance that field boundary. contribute to the character of East Hagbourne).

5.17 The foreground and middle distance are considered Natural Significance - Low (besides vegetation unremarkable, being of uniform character and around the periphery of Lower End Field there are degraded by views of pylons. Only long distance very few habitat features that contribute to the views to the south east are of note due to views of character of East Hagbourne). distant hills within the AONB. 21

5.19 As demonstrated above the most notable views across Lower End Field and the wider landscape are available from a small gap between existing fencing and hedge planting adjacent to New Road, in the north, and from the Great Mead Bridleway looking south and east. It could be argued that these views do take in elements of the wider AONB and as such could presently be considered ‘Key’ views.

5.20 Views south from the edge of Didcot are partially screened. Views north and north east take in the existing urban context of East Hagbourne and Didcot (including the power station). These views do not include historic landmarks nor do they include unspoilt countryside, as such these views cannot be considered ‘Key’ views.

5.20 In addition to the suggested rewording of Policy VC2, it is our contention that key views C and D, north and west, across Lower End Field should be deleted. Furthermore due to its inaccessibility and screening by existing trees view B should similarly be deleted. 22 Policy H3

6.0 SECTION 6

Policy H3 - Housing Allocation

6.1 Policy H3 proposes the allocation of a site for 6.3 Without Policy H3 it would be difficult to argue approximately 74 dwellings. This site already that the EHNDP contains policies and allocations has the benefit of outline planning permission to meet its identified housing requirement. (reference P17/S2469/O, granted January Therefore it would appear that this housing 2018) and planning conditions dictate that the allocation has only been included so that the development is carried out in accordance with an EHNDP is armed against the presumption in illustrative masterplan and series of parameters favour of sustainable development. This does plans. Policy H3 seeks to influence the layout, not contribute to the achievement of sustainable access, landscaping and appearance of the development, as required by the basic conditions. development; matters which are already to be dealt with through reserved matters applications pursuant to the illustrative masterplan and parameters plans subject of this outline planning permission. Therefore (unless it is to conflict with the outline planning permission) Policy H3 serves very little purpose and a site allocation is certainly not necessary to enable the land to be developed.

6.2 It is suggested that this housing allocation has been included in the EHNDP purely as an attempt to bolster the EHNDP in terms of paragraph 14 of the Framework. That is, in situations where the presumption applies to applications involving the provision of housing, the adverse impact of allowing development that conflicts with the neighbourhood plan is likely to significantly and demonstrably outweigh the benefits, provided that (inter alia) the neighbourhood plan contains policies and allocations to meet its identified housing requirement. 23 Summary

7.0 SECTION 7

7.1 In summary, we consider that the following changes should be made to the EHNDP in order for it to meet the basic conditions:

• The plan (Fig 4) and text referring to the Didcot • Policy H3 should be deleted as it serves no Garden Town Delivery Plan (GTDP) (the last 3 useful purpose and appears to have been paragraphs on page 24 and the first paragraph included purely as an attempt to bolster on page 25) should be deleted from the EHNDP. the EHNDP in terms of paragraph 14 of The Moreover, in our opinion, the East Hagbourne Framework. Green Buffer Assessment should be subjected to further scrutiny on the basis that conclusions drawn concerning the extent of proposed green buffers lack robust argument. The GTDP is subject of outstanding objections, it should carry very limited weight as an evidence base document in the making of the EHNDP, it does not have the evidential support of a DPD and it should not gain status by being referred to in the EHNDP.

• Policy VC1a should be deleted because it proposes an onerous level of landscape protection, which is in conflict with the Framework, and would not contribute to the ach ievement of sustainable development.

• Policy VC2 should be amended to provide a more balanced approach to the protection of important views. Also, views identified as B, C and D on Figure 7 should be deleted. prepared by:

and on behalf of: Nurton Developments Ltd