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East Hagbourne Submission Consultation Planning Policy South Oxfordshire District Council 135 Eastern Avenue Milton Park Milton OX14 4SB

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East Hagbourne Submission Consultation Planning Policy South Oxfordshire District Council 135 Eastern Avenue Milton Park Milton OX14 4SB Your ref: East Hagbourne Neighbourhood Plan Our ref: 38631 DD: 01908 25 E: [email protected] Date: 04/01/2019 East Hagbourne Submission Consultation Planning Policy South Oxfordshire District Council 135 Eastern Avenue Milton Park Milton OX14 4SB Dear Sir/Madam EAST HAGBOURNE NEIGHBOURHOOD DEVELOPMENT PLAN REGULATION 14 CONSULTATION I write on behalf of my client Catesby Estates Ltd in response to the above consultation in order to comment on the Draft Neighbourhood Plan. My client has a land interest at east of Park Road, Didcot. Their land interest is located within the East Hagbourne Neighbourhood Plan Area and it is considered that, in part, it has potential to be allocated for residential development. A Constraints and Opportunities plan and a Development Framework Plan showing how the site could be developed is enclosed with this representation. Catesby Estates Ltd has submitted previous representations which we do not consider have been given due consideration as part of the Neighbourhood Plan preparation process. Catesby Estates Ltd has numerous concerns in relation to the Draft Neighbourhood Plan which are outlined as part of this representation. I have summarised these key issues below: − The East Hagbourne Neighbourhood Plan has failed to allocate any sites for development – the site chosen is already committed; − The pre-screening process used as part of the site allocation methodology does not factor in the relationship of the East Hagbourne Neighbourhood Area to the nearby growth town of Didcot and does not properly assess the sustainability of sites; − Coscote Fields Green Gap in its current form is not justified or appropriate ● Evidence produced by South Oxfordshire District Council, specifically the Landscape Capacity Assessment for Sites on the Edge of the Four Towns in South Oxfordshire (September 2017), has not been used to inform the Neighbourhood Plan. ● East Hagbourne Village Landscape Character Assessment and East Hagbourne Green Buffer Assessment (September 2018) both use broad areas to assess the landscape in the Neighbourhood Plan Area without sufficient justification, and they do not give due consideration to the location of sites in relation to Didcot. John Ormond House, 899 Silbury Boulevard, Central Milton Keynes MK9 3XJ T: 01908 202190 E: [email protected] W: bidwells.co.uk Bidwells is a trading name of Bidwells LLP, a limited liability partnership, registered in England and Wales with number OC344553. Registered office: Bidwell House Trumpington Road Cambridge CB2 9LD. A list of members is available for inspection at the above address. Please ensure you’re familiar with our Privacy Notice which is available here: bidwells.co.uk/privacy − The Neighbourhood Plan fails to give due consideration to the sustainability of sites and their relationship to Didcot when giving significant weight to the protection of views. My client does not consider that the East Hagbourne Neighbourhood Plan in its current form meets Basic Conditions A, D and E as is required for a Neighbourhood Plan to progress to referendum. As a result, the Draft East Hagbourne Neighbourhood Plan needs to be amended based on the concerns raised as part of this representation and should not proceed in its current form. 1.0 Policy H1 ‘Housing Provision’ and Policy H3 ‘Housing Allocation’ 1.1 Policy H1 ‘Housing Provision’ states that ‘New residential development in East Hagbourne will be focused in the housing allocation (Policy H3), which will deliver approximately 74 dwellings.’ 1.2 Policy H3 ‘Housing allocation’ states that ‘Site 5, part of Western Village Plotlands, situated on Main Road adjacent to Hagbourne Village Hall, is allocated to provide approximately 74 dwellings.’ 1.3 As is acknowledged in the Draft Neighbourhood Plan this site already benefits from pre-existing outline planning permission. As a result, the Neighbourhood Plan cannot be considered to be ‘allocating’ development in East Hagbourne as this is already a commitment. In this regard, the Plan adds no value. 1.4 Notwithstanding the implications of the Oxfordshire Growth Deal, as the Neighbourhood Plan is not allocating any land for residential development, it is not protected by the stipulations set out under paragraph 14 of the National Planning Policy Framework (NPPF), whereby, if a Neighbourhood Plan is less than 2 years old, contains policies and allocations to meet its identified housing requirement, the LPA can demonstrate a 3-year housing supply and the LPA’s housing delivery test was at least 45% of that required over the previous 3 years, East Hagbourne could resist development not in accordance with the Neighbourhood Plan. 1.5 It must also be noted that in our view by failing to allocate a site for development the East Hagbourne Neighbourhood Plan fails to meet Basic Condition D of neighbourhood planning, which requires a neighbourhood plan to seek to achieve sustainable development. This is particularly relevant given the fact that the neighbourhood plan boundary abuts Didcot – the most sustainable settlement in the District and provides an opportunity to proactively plan for the sustainable growth of the town. 1.6 Paragraph 8 of the National Planning Policy Framework (NPPF) sets out there are there dimensions to sustainable development – economic, social and environmental. Paragraph 8 clarifies that these dimensions are interdependent and need to be pursued in mutually beneficial ways. Through the non-allocation of land in the plan, both the economic and social objectives of sustainable development are not achieved and, as discussed in more detail later in this representation, there is insufficient evidence of landscape harm to justify the non-allocation of sites, specifically our client’s land, on environmental grounds. Page 2 1.7 Additionally, the Plan does not meet Basic Condition D which require a Neighbourhood Plan to have regard to national policies and advice; particularly Paragraph 7 of the NPPF which states that the purpose of the planning system is to contribute to the achievement of sustainable development. The Neighbourhood Plan does not consider the negative impact that failing to allocate land will have on the social, environmental and economic dimensions of sustainability in the East Hagbourne Neighbourhood Plan Area. 1.8 Paragraph 11 of the NPPF states that ‘plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change’. (our emphasis underlined). The non-allocation of any sites put forward for consideration on the edge of Didcot in favour of a previously committed site in the village does not reflect a positive approach to meeting ongoing housing need. The non-allocation of sites also means the Neighbourhood Plan does not have any flexibility built in and as set out further below, will be at risk of quickly being out of date. 1.9 Through failing to allocate a site for development Basic Condition E has also not been met which requires the Neighbourhood Plan to be in general conformity with the strategic policies contained in the development plan for the area. The South Oxfordshire Core Strategy (2012) places a significant emphasis on the growth of Didcot as a settlement, as does the emerging replacement Local Plan. 1.10 The emerging Local Plan is progressing Didcot as a Garden Town. The emerging Local Plan 2033 states in ‘Policy STRAT1: Overall Strategy’ that proposals should be ‘focusing major new development in Science Vale including Didcot Garden town and Culham so that this area can play an enhanced role in providing homes, jobs and services with improved transport connectivity.’ In this regard, although the further growth of Didcot will be planned through the development of a masterplan for the town, in line with the principles set out in the emerging Local Plan, the Neighbourhood Plan provides an opportunity to actively plan for the appropriate growth of the town into the Parish area. 1.11 It should be noted that we will be making representations to the upcoming consultation on the emerging Plan to the affect that more land is needed surrounding Didcot and that our client’s land should in part be allocated for development, in line with the Local Planning Authorities own evidence (discussed later in this representation). 1.12 Whilst the Planning Practice Guidance is clear that Neighbourhood Plans can be bought forward ahead of emerging Local Plans the same guidance also sets out that that the reasoning and evidence behind emerging plans is relevant to the development of Neighbourhood Plans and satisfying the basic conditions. The Planning Practice Guidance (ref 41-009-20160211) sets out: Although a draft neighbourhood plan or Order is not tested against the policies in an emerging Local Plan the reasoning and evidence informing the Local Plan process is likely to be relevant to the consideration of the basic conditions against which a neighbourhood plan is tested. 1.13 Should this Neighbourhood Plan be made in its current form it will be seeking to restrict housing development on the edge of a sustainable settlement such as Didcot, which is not consistent with the aspirations of Didcot as a growth town, does not represent sustainable development and also risks leaving the Neighbourhood Plan immediately out of date, should our future representations to the emerging Local Plan lead to an amendment, allocation our client’s land for development. Page 3 1.14 In summary, we consider that policies H1 and H3 of the Draft East Hagbourne Neighbourhood Plan do not meet the requirements of Basic Conditions D, A and E. A change is sought which allocates our clients and to the extent shown on the enclosed plans. Such an amendment would help to overcome the issues identified above and would be consistent with other policies of the plan, as discussed further below. 2.0 Site Allocation Methodology 2.1 As has been established above, the Draft Neighbourhood Plan does not allocate a site for development given that the site selected is already a housing commitment.
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