Radley Neighbourhood Plan Submission Draft December 2017 (NPSD)

Home , Boars Hill, East Hanney, North Hinksey, Radley, South Hinksey

Radley Neighbourhood Plan

Submission Draft December 2017

Response by Arnold White Estates Ltd

Project reference GP 004 Date 27 February 2018

Gardner Planning Ltd Down Ampney Bendlowes Road Great Bardfield Essex CM7 4RR

COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Gardner Planning Ltd. Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

CONTENTS

1. Introduction 2. Policy and Guidance 3. Comment on any change in the NP Submission Draft 4. The Case for Radley South 5. Conclusions

Appendices

1. Radley South Concept Plan 2. The Response to the NP Draft 1

2 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

1.0 INTRODUCTION

1.1 This Response, which has been prepared by Gardner Planning Ltd (GPL) on behalf of Arnold White Estates Ltd (AWEL), is to the Radley Neighbourhood Plan Submission Draft December 2017 (NPSD). The response to the First Consultation Draft (D1 Report) was submitted on 30.1.17 and the Second Draft (D2 Report) 18.10.17.

1.2 The Submission Draft is very little changed from the Draft 2 version. Thus, this NPSD Response incorporates the D2 Report for completeness to assist the Neighbourhood Plan Inspector of our representations when assessing the NP. However, when forwarding this Response to the Inspector, it is important that the D1 Report is also forwarded, so that is Appendix 2 to this latest Response.

1.3 Radley Parish Council (RPC) has published a response to the comments made1, and these include those made on behalf of AWEL. These are reproduced and commented on in this Response at the end of the relevant sections.

1.4 AWEL is promoting a development known as Radley South on behalf of the site owners. GPL participated in the Vale of White Horse Local Plan (VWHLP) Examination Part 1. Part 2 of the VWHLP reached the ‘preferred options’ in March 2017 and a ‘Publication’ version was published in October 2017. Representations on behalf of AWEL were submitted in November 2017.

1 Radley Neighbourhood Plan Second Consultation Draft, September 2017, Analysis of Comments Received, and RPC’s Response. (undated)

3 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

2.0 POLICY AND GUIDANCE

National

2.1 Reference was made to the National Planning Policy Framework (NPPF) in the D1 Report.

2.2 The Department for Communities and Local Government (DCLG) published ‘Fixing our broken housing market’ (the Housing White Paper HWP) in February 2017, followed by ‘Planning for the right homes in the right places: consultation proposals’ (September 2017) (CP).

2.3 These documents represent the Government’s policy emphasis to significantly increase housing supply. The Prime Minister’s Foreword in the HWP included (emphasis in bold):

I want to fix this broken market so that housing is more affordable and people have the security they need to plan for the future. The starting point is to build more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need to build many more houses, of the type people want to live in, in the places they want to live. To do so requires a comprehensive approach that tackles failure at every point in the system.

2.4 ‘Every point in the system’ includes Neighbourhood Plans.

2.5 The CP focuses on a simplified methodology for calculating housing need and signals that the NPPF will be revised in 2018.

2.6 Further Government announcements about increasing housing supply were in the Autumn Budget on 22.11.17.

2.7 The Oxford-Milton Keynes-Cambridge Growth Corridor was announced in March 2017 which seeks significant new housing (at levels well above those currently being planned) to support the economic potential of this vibrant sub-region. Radley cannot ignore that it is part of this growth corridor.

4 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

2.8 NPSD mentions that Oxford CC are proposing a new Park and Ride site alongside the A34 Lodge Hill Junction, which could link to the National Infrastructure Commission’s proposal for an Oxford-Cambridge Expressway. This would be “in the north of the parish”.2

2.9 Such proposals increase the connectivity of Radley and sustainability of new development there.

Local: The Development Plan

2.10 Many of the policies of the Vale of White Horse District Council (VWHDC) Local Plan 2011 (adopted 2006) are now superseded by the Adopted Local Plan 2031 Part 1 (LP Part 1). The remaining policies of the 2011 Plan will be superseded on adoption of the Part 2, 2031 Local Plan (LP Part 2).

2.11 VWHDC is preparing a Local Plan in two Parts. Part 1: Strategic Sites and Policies was adopted on 14.12.16. Part 2 will identify additional sites for development is planned to be ‘submitted’ in February 2018 and adopted by December 2018 3.

2.12 The publication of the Draft 1 NP in December 2016 overlapped with the LP Part 2 Preferred Approach (LP2PA) in February 2017. The publication of the Draft 2 NP overlapped with the Publication Pt 2 LP.

2.13 The publication of the Submission Draft before submission and examination of the LP Part 2 is similarly premature. At every stage the NP argues that strategy, sites and housing numbers are in accordance with the emerging LP, even though un-tested by examination. It is possible that when the South Radley site is examined in the LP process (May 20184) it will be claimed that ‘the site is not in the NP’. This is a circular argument.

2 NPSD p19 3 VWH LDS Sept 16 4 ditto

5 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

Housing numbers and distribution

2.14 The LP Part 1 Core Policy 4 makes provision for the District of 20,560 homes over the 20- year period to March 2031. The Policy divides the District into three Sub-Areas, and Radley is within the Abingdon-on-Thames and Oxford Fringe Sub-Area, which has allocated sites totalling 1,790 homes, including 240 for the site ‘North-West Radley’ (others may be in Radley Parish but are extensions of Abingdon and Kennington).

2.15 Core Policy 8 also deals with housing in the Abingdon-on-Thames and Oxford Fringe Sub- Area. In addition to the 1,790 homes on strategic sites a further “962 dwellings remain to be identified and will be allocated through the Local Plan 2031 Part 2 or Neighbourhood Development Plans or through the Development Management process”(emphasis added).

2.16 In addition to these allocations (which are all to satisfy the District housing needs), there is a commitment to contribute to Oxford’s unmet housing needs in Core Policy 2: Cooperation on Unmet Housing Need for Oxfordshire, as follows (emphasis added):

The Council will continue to work under the ‘duty-to-cooperate’ with all other Oxfordshire local authorities on an ongoing basis to address the objectively assessed need for housing across the Oxfordshire housing market area.

As a first step, Vale of White Horse District Council has sought to accommodate the housing need for Vale of White Horse District in full in the Vale of White Horse Local Plan 2031 Part 1. The Council recognises that Oxford City is unlikely to be able to accommodate the whole of its new housing requirement for the 2011-2031 period within its administrative boundary.

To ensure Oxford’s unmet need is addressed, the Council will allocate sites to contribute towards Oxford’s unmet housing need within the Local Plan 2031: Part 2, to be submitted to the Secretary of State, within two years of adoption of the Local Plan 2031: Part 1. This will ensure that unmet need is considered and planned for in a timely manner and is tested through a robust plan-making process in accordance with national policy, national guidance, …

6 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

2.17 VWHDC accepted the recommendation of the Oxfordshire Growth Board which assessed Oxford’s unmet need and agreed to accommodate an extra 2,200 homes5. However, this process now needs reconsideration because South Oxfordshire District, which published its Publication Local Plan in October 2017, has agreed not to accommodate 1,200 homes of its originally allocated unmet Oxford needs6. The shortfall of 1,200 homes will need to be made up., most likely in the area closest to Oxford - the VWH Abingdon and Oxford Fringe Sub-Area. This will have implications for the Radley NP.

5 VWHDC Vale of White Horse Local Plan Update Bulletin 4 – October 2016 6 3,750 homes in LP Policy STRAT3, p33, not the 4,950 of the Growth Board Report of September 2016

7 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

3.0 COMMENT ON ANY CHANGES IN THE SUBMISSION DRAFT PROPOSALS

3.1 There is much to support in the Draft NP, but without a realistic housing allocation which recognises the ‘bigger picture’ some proposals have a doubtful prospect of implementation. Some proposals are labelled ‘PP’ (Planning Policies) which is decisive, others are CA (Community Action) which can be seen as aspirational.

3.2 The D1/D2 Reports identified the following matters, and this Response demonstrates that these submissions have not been adequately addressed.

Housing

3.3 The NPSD makes no changes to housing allocations: Radley is set to contribute just 25 additional homes to meet its share of District and Oxford needs, when it is a recognised key sustainable settlement in the important Abingdon and Oxford Fringe Sub-Area and part of the Oxford-Milton Keynes-Cambridge Growth Area.

Reasonable Alternatives

3.4 There is still no supporting evidence that ‘reasonable alternatives’ have been investigated. The investigation of ‘reasonable alternatives’ is required by PPG7 (extract) (emphasis in bold):

The strategic environmental assessment should outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives. It should provide conclusions on the overall environmental impact of the different alternatives, including those selected as the preferred approach in the neighbourhood plan. Any assumptions used in assessing the significance of effects of the neighbourhood plan should be documented.

The development and appraisal of proposals in the neighbourhood plan should be an iterative process, with the proposals being revised to take account of the appraisal findings. This should inform the selection, refinement and publication of the preferred approach for consultation.

7 PPG Paragraph: 038 Reference ID: 11-038-20150209 Revision date: 09 02 2015

8 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

3.5 There is no adequate explanation of the process which arrived at the identification of the two housing sites of the ‘old coal yard’ and the ‘central allotments’. The Sustainability Appraisal does is not consider ‘reasonable alternatives’ to these sites as required, looking only at the ‘Radley Lakes’ environmental improvement proposals, and stating:

5.1.3 More specifically still, this part of the report presents information regarding the consideration of reasonable alternative policy approaches to the Radley Lakes area, in the south of the plan area - see Figures 5.1. Planning for the Radley Lakes area is of central importance to the achievement of RNP objectives (iv) and (v), as discussed further below.

What about other plan issues?

5.1.4 Whilst the plan will set policy to address a range of other thematic issues through development management policy, these policy areas have not been a focus of alternatives appraisal, and hence are not discussed further here, within Part 1 of the report (but are a focus of Part 2).

3.6 The ‘thematic issues’ are environmental, not land use or site-specific issues.

3.7 This lack of evidence and examination of reasonable alternatives seems contrary to Government Planning Practice Guidance:

PPG 040 Proportionate, robust evidence should support the choices made and the approach taken. The evidence should be drawn upon to explain succinctly the intention and rationale of the policies in the draft neighbourhood plan.

PPG 042 A neighbourhood plan can allocate sites for development. A qualifying body should carry out an appraisal of options and an assessment of individual sites against clearly identified criteria. Guidance on assessing sites and on viability [is provided - see PPG].

RPC Comments8 on para 3.4 - 3.6 above

The planning authority has not identified any need to find sites for additional housing in Radley, either through Part 2 of the Local Plan or the Neighbourhood Plan, and RPC sees no case to allocate more sites through the NP in the absence of

8 Radley Neighbourhood Plan Second Consultation Draft, September 2017, Analysis of Comments Received, and RPC’s Response. (undated) p1

9 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

such guidance. The Parish Council’s view is that the development already planned under the Local Plan Part 1 is more than enough for the community to absorb. The identification of two small sites where development will be supported is not driven by a concern to provide more housing in the village. The old coal yard has been an eyesore for many years and development may present the only real prospect of getting it improved. The allotment site has potential as a central site for a larger village shop or other community facilities, which might perhaps combined with some housing development. On the need to consider alternatives for development of the old coal yard site, the VWHDC Screening Opinion concluded: “our opinion is that there will be good potential for RPC to develop appropriate policy, in consultation with VoWH District Council and other interested parties (including Historic England), which ensures that significant negative effects are avoided or fully mitigated. On this basis, it does not seem likely that significant effects will result from policy for this site. Equally, it is difficult to envisage any benefit to examining the emerging policy approach, and alternatives, through a formal SEA process”. On the proposal to support possible development of the allotment site, the VWHDC Screening Opinion concluded that: “As this site is located within the built up area, there is a degree of existing policy support for development. As such, the effect of the NP will not be to ‘allocate’ the site, in the strict sense.”

Response

3.8 The assertion that “The Parish Council’s view is that the development already planned under the Local Plan Part 1 is more than enough for the community to absorb.” is both unexplained (in terms of what?) and not supported by any evidence.

3.9 The two sites, the Old Coal Yard and the Allotments, are housing proposals of the NP (e.g. “limited housing development” p17) and enshrined in NP Policies PP.1 and PP.2. The justification for allocating the sites (“derelict brownfield” and “not in the Green Belt”) are common enough in any local or neighbourhood plan, but do not preclude assessment of ‘reasonable alternatives’ in the SEA (required by PPG 040, 042). VWHDC provide no explanation of why these two sites are ‘not allocations’ nor why, therefore, the the SEA is precluded from identifying and assessing ‘reasonable alternatives’.

3.10 The objection that the NP SEA fails PPG, and is therefore deficient, remains.

10 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

Community Facilities

3.11 The relocation of the Village Hall and playing field is clearly contentious, and has been an on-going problem since 2008, as recorded on pp 19, 21 of the Draft1 NP. The existing site is owned by Radley College and leased to RPC. Playing fields to the south are on land owned by clients of AWEL.

3.12 After considering two proposals by owners of the land (Radley College and AWE on behalf of the owners of the playing field) to provide improved facilities, these are rejected in favour of ‘retaining the facilities on the current site’ (without further detail and without decisive comment on third party land ownership) and to support additional provision outside the village on the North Abingdon site9.

3.13 AWEL continues with the offer for a new village hall and playing field site as part of the Radley South proposals as shown on the concept plan, Appendix 2.

RPC Comments10 on para 3.10 - 3.12 above

AWEL and Radley College’s proposals are dependent on permission to develop more housing on Green Belt land and are rejected for those reasons.

Response

3.14 No comment is made on the merits of securing a permanent site for the playing fields and a site for a new village hall, which is in poor condition.

Radley Lakes

3.15 Whilst this is a central proposal11 there is still no explanation within the NP of ‘delivery’, ‘funding’, or ‘viability’. Also, nor is there still no such explanation for the equally important new access road to Audlett Drive, Abingdon to relieve Thrupp Lane12. Clearly,

9 NPSD para 4.4.2 p 27 10 Radley Neighbourhood Plan Second Consultation Draft, September 2017, Analysis of Comments Received, and RPC’s Response. (undated) p1 11 ditto para 4.6.3, PP.10, CA.10 p37 12 ditto para 4.7.3

11 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

this would be an expensive project and there would be many other calls on funds raised by way of S106 and CIL. However, with only modest housing sites as proposed in the NPSD, that funding would be also modest. Funds derived from the other two strategic sites would surely be directed to Abingdon and Kennington. The important contribution which could be made by an additional housing site at Radley South is not mentioned.

RPC Comments13 on para 3.13 above

RPC’s proposals for funding are in Part 5 of the Plan. Some s.106 funding for the Radley Lakes strategy has already been secured.

Response

3.16 NPSD Para 5.3 states as follows:

The costs, especially of the access, could be substantial and it is unlikely in practice that individual beneficiaries will be willing to make sufficient contribution unless a range of parties are seen to be willing to do so. In the case of environmental projects, grants might be available but these are typically for capital costs and it will be important to attract or generate revenue funding. RPC will make its own financial contribution to help lever contributions from others. This does not mean that RPC contributions will be ruled out for other projects, but much will depend on detailed costings and the availability of other sources of finance. It is unlikely that there will be enough funding for everything and a gradual phased approach is likely to be needed.

3.17 There is no indication in the NPSD, or any supporting material, of even broad costs or the likelihood of the nature or size of any funding. The claim that “Some s.106 funding for the Radley Lakes strategy has already been secured” is unsupported by source or amount. From that source, however, some estimates of similar funding from sites already allocated could be provided, but are not.

3.18 The objection remains that there is still no explanation within the NP of ‘delivery’, ‘funding’, or ‘viability’ for Radley Lakes and the access road to Audlett Drive. Radley

13 Radley Neighbourhood Plan Second Consultation Draft, September 2017, Analysis of Comments Received, and RPC’s Response. (undated) p1

12 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

South would be a source of s106 funding and is closest to the lakes with access off Thrupp Lane. That is a matter to be weighed in the planning balance.

Highways and Access

3.19 This Report supports all the Draft NP’s policies and proposals. The new roundabout junction for Whites Lane, Foxborough Road and Thrupp Lane14 is especially supported but, again, there is no explanation about delivery/funding etc. Again, the important contribution which could be made by an additional housing site at Radley South is not mentioned.

14 ditto Map 8 p38

13 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

4.0 THE CASE FOR RADLEY SOUTH

4.1 The sustainability of Radley as a settlement and its suitability for making a meaningful contribution to the housing shortfall, of the Abingdon and Oxford Fringe Sub-Area and the un-met needs of Oxford, has been demonstrated in Section 2 above.

4.2 Radley is a sustainable settlement with its own station and ready access to Oxford by rail. It is acknowledged in the Cabinet Report (7.8.15) that Radley is one of the “most sustainable larger village” having “excellent public transport links to Oxford, with a railway station”. This was endorsed by the LP Part 1 Inspector: Radley is “a ‘larger’ village with local services, including a station with direct trains to Oxford, Didcot and London”15

4.3 There has been no assessment of ‘reasonable alternatives’ to the two small sites allocated in the NPSD as required and described in Section 3 above.

4.4 The merits of Radley South were set out in the D1/D2 Reports and remain entirely valid. The Concept Plan is Appendix 1 to this Response. The sustainability of Radley, and its ability to contribute to the growth needs of the area, are matters not addressed by the Neighbourhood Plan. The merits of the Radley South site, and the contributions it would make are not recognised:

 housing needs, including affordable housing  the realisation of the Radley Lakes proposals  the provision of a village hall and recreational hub  improved access to Thrupp Lane

RPC Comments16 on paras 4.1 - 4.3 (and D1 Report attached as Appendix 1)

RPC remains opposed to development on the South Radley site on the grounds set out in line 3 above and because the site is in Green Belt.

15 Inspector’s Final Report 30.11.16 para 83 16 Radley Neighbourhood Plan Second Consultation Draft, September 2017, Analysis of Comments Received, and RPC’s Response. (undated) p1

14 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

Response

4.5 There is no real response to the many claimed advantages of the Radley South site, nor any acknowledgement of Government’s policy for a substantial increase in housing delivery.

4.6 There is no ‘line 3 above’ so that the only objection is that the site is in the Green Belt. This it has in common with many other sites allocated in Local and Neighbourhood Plans across the country, in Oxfordshire, in the VWH District and in the Radley NP. It is not an absolute constraint, nor as the complete explanation as to why, in the context of housing need and being a sustainable settlement in a growth area, Radley South has been rejected, nor even fully evaluated. The objection to its exclusion from the NP remains.

15 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

5.0 CONCLUSION

5.1 This Response has been submitted on behalf of AWEL in response to the consultation on the Radley Neighbourhood Plan Submission Draft, December 2017. It is a modified version of the response made in October 2017 on the Second Consultation Draft

5.2 There are no substantive changes in the NPSD which alter the substance of our original objections. To avoid repetition, this Response should be read together with that on the First Consultation Draft submitted in January 2017 (attached as Appendix 2).

5.3 The publication of the Submission Draft before submission and examination of the LP Part 2 is similarly premature. At every stage the NP argues that strategy, sites and housing numbers are in accordance with the emerging LP, even though un-tested by examination. It is possible that when the South Radley site is examined in the LP process (May 201817) it will be claimed that ‘the site is not in the NP’. This is a circular argument.

Housing provision

5.4 Government policy in the NPPF and especially the Housing White Paper places even more emphasis on increasing delivery of more housing. The NPSD’s proposal for an extra 25 homes is well below that expectation for a highly sustainable settlement within the newly recognised Oxford-Milton Keynes-Cambridge Growth Corridor.

5.5 RPC comments in the ‘Analysis of Comments Received and RPC’s Response’ that further housing development is not required in Radley because “development already planned under the Local Plan Part 1 is more than enough for the community to absorb”. This is both unexplained (in terms of what?) and not supported by any evidence.

Assessment of reasonable alternatives for housing sites

5.6 The assessment of reasonable alternatives is a requirement of the SA/SEA (see para 3.4 above). There is still no obvious assessment of reasonable alternatives options before

17 ditto

16 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

two (small) sites are proposed for development. Neither the NPSD or supporting documents (including the Strategic Environmental Assessment) examine ‘reasonable alternatives’ for housing sites. The ‘Analysis of Comments Received and RPC’s Response’ seeks to dismiss this objection by stating that the two housing sites identified in the NPSD are not ‘allocations’. This cannot be correct because the two sites (The Old Coal and the Central Allotments) are enshrined in NP Policies PP.1 and PP.2. The justification for allocating the sites (“derelict brownfield” and “not in the Green Belt”) are common enough in any local or neighbourhood plan, but do not preclude assessment of ‘reasonable alternatives’ (required by PPG 038, 040, 042).

Radley South benefits

5.7 As well as a contribution to housing needs, Radley South offers benefits to the community.

5.8 The RNP still contains many worthy aspirations which need to be turned into firm delivery proposals. The Draft NP highlights the dissatisfaction with the existing Village Hall and playing fields. It also has a worthy, but ambitious, strategy for creating ‘Radley Lakes’ and a new access to Audlett Drive, Abingdon. The school and community shop also seek support. These initiatives may founder through lack of funding.

5.9 There continues to be a strong case for allocating Radley South, not least because of the extra funding it could offer to the community facilities. Radley South would provide a new site to its east providing space for a new Village Hall, football pitches, cricket pitch, children’s play area and a carpark. This would be major benefit to the village and resolve the problems with the existing site. If that were to be developed too (owned by Radley College but leased by RPC) then it could fund the works and build the Hall. Radley South could also make contributions to road improvements and the realisation of Radley Lakes.

5.10 Offers of an additional site (Radley South) to provide a permanent site for playing fields and village hall are dismissed without comment on the merits of the offer, merely stating that Radley South is unacceptable being in the Green Belt. Radley South would

17 Radley Neighbourhood Plan, Submission Draft Dec 17 Gardner Planning on behalf of Arnold White Estates

also provide funding for Radley Lakes, but this is also dismissed, the NPSD claiming that some funding is already available. There is no indication in the NPSD, or any supporting material, of even broad costs or the likelihood of the nature or size of any funding. The claim that “Some s.106 funding for the Radley Lakes strategy has already been secured” is unsupported by source or amount. From that source, however, some estimates of similar funding from sites already allocated could be provided, but are not.

5.11 Allocation of sites in the Green Belt would be in common with many other sites allocated in Local and Neighbourhood Plans across the country, in Oxfordshire, in the VWH District and in the Radley NP. It is not an absolute constraint, nor is there a complete explanation as to why, in the context of housing need and being a sustainable settlement in a growth area, Radley South has been rejected, nor even fully evaluated.

5.12 AWEL will continue to seek to work with the Parish Council and the community, but will pursue, in every way possible, the allocation of the site and the recognition of the benefits that could be realised for Radley.

18 Radley Neighbourhood Plan, Submission Draft December 2017

Response on behalf of AWEL

Appendix

1. Radley South Concept Plan

11 T J 1 AMES T

a 6 75 E t

RR 2 3 o

21 8 A CE 4

1 85 The Bowyer Arms (PH) 75 77 73

3 1 Radley Station

WHITE

' S

L 59 A 28 N

108 6

T 98 4

47 URNE 5

9 0 C

S 5

E 3 1

1 7 6 3

7 Station 78

25 72

ROAD 27 GH 68 OROU

FOXB

64 1 2 B

13 4 6 O 41 W YER

4 ENT SE CRESC NHOU

3 STO

54 BADGERS COPSE

2 13

Hid 0 52

12 6 1 7

co 1

1 1

8 36 Co nifers

Ashbrook

3 4

GO OSEA CR E 1

6 1

3 5

Hall 1 2

NORFOLK CL

6 2 4

DRYSDALE CLOSE

4 1

Village Hall

Car park

Play area

T HRUP Allotments P L

ANE

Conchiglia

Rettford

Goose Acre Farm

T HR

P LA

Pond

Radley South proposed development Proposed boundary planting

Other available land in the same ownership Proposed street trees

Current Village Hall and playing ﬁelds Proposed allotments

Home Farm Proposed playing ﬁelds

Home Farm Barn Proposed open space DRAFTProposed residential Proposed footpath/cycleway

Sustrans Route 5

Arnold White Estates Ltd 1-46_100.A | 30-01-2017 | 1:4,000@A4 built form resource Radley Neighbourhood Plan 0 50 150 Consultation

01865 261456, Oxford Centre for Innovation, New Road, Oxford OX1 1BY [email protected] www.builtformresource.com Radley Neighbourhood Plan, Submission Draft December 2017

Response on behalf of AWEL

Appendix

2. The Response to the NP Draft 1 Radley Neighbourhood Plan

Consultation Draft December 2016

Response by Arnold White Estates Ltd

Project reference GP 004 Date 30 January 2017

Gardner Planning Ltd Down Ampney Bendlowes Road Great Bardfield Essex CM7 4RR

07887 662166 [email protected]

COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Gardner Planning Ltd. Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

CONTENTS

1. Introduction 2. Policy and Guidance 3. Summary of the Draft NP Proposals 4. The Case for Radley South 5. Conclusions

APPENDICES

1. Radley South Concept Plan including relocated Village Hall and pitches. 2. Extract from VWHDC/Kirkham Report on Radley South 3. VWHDC submission on Green Belt sites to LP Part 1 Examination and Adopted Sub- Area Plan

2 Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

1.0 INTRODUCTION

1.1 This Report, which has been prepared by Gardner Planning Ltd (GPL) on behalf of Arnold White Estates Ltd (AWEL), is the response to the Radley Neighbourhood Plan (RNP) Consultation Draft December 2016 (Draft NP). Reponses must be made by 10.2.17. This Report is a fuller response as an alternative to the ‘response form’.

1.2 AWEL is promoting a development known as Radley South on behalf of the site owners. GPL participated in the Vale of White Horse Local Plan (VWHLP) Examination Part 1 in September 2015 (Stage 1) and February 2016 (Stage 2). Part 2 of the Plan is being prepared with the programme identifying publication of the ‘preferred options’ in February 2017. AWEL has submitted an ‘expression of interest’ for the Radley South site which will be considered for inclusion in VWHLP Part 2.

2.0 POLICY AND GUIDANCE

National

2.1 The following are extracts from the Government’s Framework (NPPF) or Guidance (PPG)1 which are relevant (emphasis added):

PPG 042 A neighbourhood plan can allocate sites for development. A qualifying body2 should carry out an appraisal of options and an assessment of individual sites against clearly identified criteria. Guidance on assessing sites and on viability [is provided - see PPG].

1 National Planning Policy Framework (March 2012) and Planning Practice Guidance (web based) 2 PPG 014 qualifying bodies are a parish or town council, a neighbourhood forum, a community organisation

3 Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

PPG 006 Can town/parish councils and designated neighbourhood forums (qualifying bodies) preparing neighbourhood plans use this guidance?

Town/parish councils and designated neighbourhood forums (qualifying bodies) preparing neighbourhood plans can use this guidance to identify specific local needs that may be relevant to a neighbourhood but any assessment at such a local level should be proportionate. Designated neighbourhood forums and parish/town councils can also refer to existing needs assessments prepared by the local planning authority as a starting point.

The neighbourhood plan should support the strategic development needs set out in Local Plans, including policies on housing and economic development. The level of housing and economic development is likely to be a strategic policy.

PPG 009 Can a neighbourhood plan come forward before an up-to-date Local Plan is in place?

Neighbourhood plans, when brought into force, become part of the development plan for the neighbourhood area. They can be developed before or at the same time as the local planning authority is producing its Local Plan.

A draft neighbourhood plan or Order must be in general conformity with the strategic policies of the development plan in force if it is to meet the basic condition. 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. For example, up-to-date housing needs evidence is relevant to the question of whether a housing supply policy in a neighbourhood plan or Order contributes to the achievement of sustainable development.

Where a neighbourhood plan is brought forward before an up-to-date Local Plan is in place the qualifying body and the local planning authority should discuss and aim to agree the relationship between policies in:

•the emerging neighbourhood plan

•the emerging Local Plan

•the adopted development plan with appropriate regard to national policy and guidance.

The local planning authority should take a proactive and positive approach, working collaboratively with a qualifying body particularly sharing evidence and seeking to resolve any issues to ensure the draft neighbourhood plan has the greatest chance of success at independent examination.

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The local planning authority should work with the qualifying body to produce complementary neighbourhood and Local Plans. It is important to minimise any conflicts between policies in the neighbourhood plan and those in the emerging Local Plan, including housing supply policies. This is because section 38(5) of the Planning and Compulsory Purchase Act 2004 requires that the conflict must be resolved by the decision maker favouring the policy which is contained in the last document to become part of the development plan. Neighbourhood plans should consider providing indicative delivery timetables, and allocating reserve sites to ensure that emerging evidence of housing need is addressed. This can help minimise potential conflicts and ensure that policies in the neighbourhood plan are not overridden by a new Local Plan.

PPG 026 Does a neighbourhood plan require a sustainability appraisal?

There is no legal requirement for a neighbourhood plan to have a sustainability appraisal as set out in section 19 of the Planning and Compulsory Purchase Act 2004. However, a qualifying body must demonstrate how its plan or order will contribute to achieving sustainable development. A sustainability appraisal may be a useful approach for doing this and the guidance on sustainability appraisal of Local Plans should be referred to.

PPG 027 Does a neighbourhood plan require a strategic environmental assessment?

In some limited circumstances, where a neighbourhood plan is likely to have significant environmental effects, it may require a strategic environmental assessment. Draft neighbourhood plan proposals should be assessed to determine whether the plan is likely to have significant environmental effects. This process is commonly referred to as a “screening” assessment and the requirements are set out in regulation 9 of the Environmental Assessment of Plans and Programmes Regulations 2004.

If likely significant environmental effects are identified, an environmental report must be prepared in accordance with paragraphs (2) and (3) of regulation 12 of those regulations.

One of the basic conditions that will be tested by the independent examiner is whether the making of the neighbourhood plan is compatible with European Union obligations (including under the Strategic Environmental Assessment Directive).

Government Statement February 20153 The Government supports the principle of local planning authorities working with those preparing neighbourhood plans where a review of the Green Belt is underway. But the Government is also clear that the responsibility for a review of the Green Belt rests with the local planning authority and must be conducted through the local plan process of consultation and examination. The rationale for this approach is to ensure the Green Belt is considered in the round of all the other planning issues the Council is addressing in its Local Plan and on an authority-wide, and indeed a cross-authority basis where appropriate.

3 Government response to the CLG Select Committee Inquiry into the Operation of the National Planning Policy Framework, para 21, February 2015)

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2.2 In summary, national planning policy requires:

• robust evidence to justify the choices made in the NP • sites can be allocated in a NP, but only after identifying options and appraising them against clearly identified criteria • the NP and LP should be developed together to avoid conflict • the NP should benefit from a Sustainability Appraisal/Strategic Environmental Assessment • the NP cannot allocate sites in the Green Belt

2.3 These points seem not to have been properly addressed in the Draft NP:

• there has been no appraisal of alternative options • the NP and LP have not been developed together - the NP should await the LP Part 2 and take on board its proposals • no justification has been given for not subjecting the NP to SA/SEA • the NP seeks to allocate a (small) site in the Green Belt, unsupported by the LP

The Development Plan

2.4 Many of the policies of the Vale of White Horse District Council (VWHDC) Local Plan 2011 (adopted 2006) are now superseded by the adopted Local Plan 2031 Part 1 (LP Part 1). The remaining policies of the 2011 Plan will be superseded on adoption of the Part 2, 2031 Local Plan (LP Part 2).

2.5 VWHDC is preparing a Local Plan in two Parts. Full Council adopted the Local Plan 2031 Part 1: Strategic Sites and Policies on 14 December 2016. Part 2 will identify additional sites for development and the future stages are as follows4:

4 VWH LDS Sept 16

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LP Part 2 dates Preferred Approach (regulation 18) then consultation Feb 2017 Pre-Submission (Regulation 19) then consultation Oct/Nov 2017 Submission to Secretary of State February 2018 Examination May 2018 Estimated date for Adoption and final publication December 2018

2.6 The publication of the Draft NP in December 2016 overlaps with the LP Part 2 Preferred Approach (LP2PA) in February 2017. There is no published program for future stages of the RNP. Both parts of the 2031 Local Plan will identify sites but the RNP can only identify additional small sites that are not in the Green Belt. Publication of the Draft NP immediately prior to the LP is clearly confusing, or perhaps a ‘lobbying’ exercise. The VWHDC’s email to GPL (5.1.17) said:

All neighbourhood plan groups will have been made aware that in preparing a neighbourhood plan in tandem with a local plan, they are at risk of not being compliant with the strategic policies of the plan. The now adopted Local Plan 2031 Part 1 contains the majority of strategic policies on which a neighbourhood plan should be in general conformity with. We are all aware that LPP2 is likely to contain some strategic policies relating to how the council addresses Oxford’s un-met housing needs, however a decision has not been made by the council on how this will be addressed.

We are still committed to proceeding with a public consultation on our preferred options in February of this year, and will be in touch again at an appropriate time following a decision on what sites are to be included in that consultation.

Housing numbers and distribution

2.7 The LP Part 1 Core Policy 4 makes provision for the District of 20,560 homes over the 20- year period to March 2031. The Policy divides the District into three Sub-Areas, and Radley is within the Abingdon-on-Thames and Oxford Fringe Sub-Area, which has allocated sites totalling 1,790 homes, including 240 for the site ‘North-West Radley’ (others may be in Radley Parish but are extensions of Abingdon and Kennington).

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2.8 Core Policy 8 also deals with housing in the Abingdon-on-Thames and Oxford Fringe Sub- Area. In addition to the 1,790 homes on strategic sites a further “962 dwellings remain to be identified and will be allocated through the Local Plan 2031 Part 2 or Neighbourhood Development Plans or through the Development Management process”(emphasis added).

2.9 In addition to these allocations (which are all to satisfy the District housing needs), there is a commitment to contribute to Oxford’s unmet housing needs in Core Policy 2: Cooperation on Unmet Housing Need for Oxfordshire, as follows (emphasis added):

2.10 VWHDC has now accepted the recommendation of the Oxfordshire Growth Board which assessed Oxford’s unmet need5:

The Council has agreed to take an apportionment of 2,200 homes of Oxford’s unmet need to be addressed within the Vale. This figure will feed into our Local Plan 2031 Part 2 process to identify suitable locations for housing to meet this need. It is necessary for the Council to consider all ‘reasonable and realistic’ alternative sites, and given the nature of the Vale and its proximity to Oxford this will need to include consideration for some Green Belt sites.

5 VWHDC Vale of White Horse Local Plan Update Bulletin 4 – October 2016

8 Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

Our Call for Sites consultation closed 22 July 2016. We are currently assessing all the sites to determine those most suitable for allocation in Local Plan 2031 Part 2.

2.11 VWHDC had previously considered which parts of the District would be most suitable for accommodating this growth. The Cabinet (7.8.15) received the Officer’s Report on the analysis of each Sub-Area to accommodate Oxford’s unmet needs. Scrutiny Committee (20.8.15) later suggested some minor changes to wording which did not change the central points. The Abingdon and Oxford Fringe Sub-Area was considered the best to accommodate Oxford’s unmet housing needs because:

This sub-area borders the south and west of the administrative area of Oxford City and contains a large area of Green Belt designated land. It contains the market town of Abingdon-on-Thames, the district’s largest and most sustainable settlement, along with the Local Service Centre of Botley, located close to the western edge of Oxford City. It also contains a number of the Vale’s most sustainable larger villages including Cumnor, Kingston Bagpuize with Southmoor, Radley and Wootton. There are already excellent public transport links to Oxford, with a railway station located at Radley and proposed new park and ride facilities.

Growth options could include a number of small scale sites already identified as suitable for proposed release from the Green Belt and/ or potential allocation of additional strategic urban extensions at sustainable settlements that are outside the Green Belt designation.

2.12 Thus, the 2,200 extra homes required for Oxford’s unmet needs are likely to be accommodated within the Abingdon and Oxford Fringe Sub-Area (in addition to the 962 already required for the District’s needs in Core Policy 8), so a total of 3,162 extra homes in addition to the 1,790 homes allocated in Part 1 of the LP. The Local Plan Part 2 will be the main vehicle to make these extra allocations.

2.13 Separately, and without the involvement of VWHDC, the Oxford Growth Board commissioned a report on how the Oxford unmet need could be addressed6. The Growth Board (GBR) says it does not allocate sites, but identifies ‘areas of search’ (said not to be an exhaustive list) and that it is up to individual Local Plans to make allocations. However, Appendix 5 lists sites, taken from the LUC Oxford Spatial Options

6 Growth Board Report (GBR) and the Spatial Options Study (SOS), 26.9.16.

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Assessment Report September 2016, that evaluated 36 ‘areas of search’ which are effectively ‘sites’.

2.14 The overall GBR ‘allocation’ of 2,200 homes to the Vale is seemingly accommodated in these 3 large sites. Abingdon North (1,100) is a northern extension to the sites already allocated in the LP Part 1 (Policy C8) which proposed 1,000 homes. The two sites at Cumnor (26 - 550 homes) and Botley (24 - 550 homes) are almost adjoining each other being west and east of the A420. They are quite different to another large site north- west of Cumnor which was proposed for release from the Green Belt in the submitted Local Plan Part 1.

2.15 The main comments provided in the LUC Report on each of these sites are (emphasis added):

ref housing site GBR comment nos 21 1,100 Abingdon North Although the area is slightly remote from Oxford it scores well for future sustainable connectivity to key employment centres. 24 550 Botley The team noted the proposal to build a Park and Ride in the area (a County commitment, but not yet in the planning process). The Project Team concluded that the areas proposed use was not well advanced in planning terms and so it was legitimate to look at alternative uses - and re-categorise as green on the basis that the area of search scores well against the key criteria of proximity to the City and sustainable transport options. 26 550 Cumnor The area scored strongly against the options assessment but has a lack of current sustainable transport options. The team concluded on balance a score of green was appropriate

2.16 It remains to be seen whether the LP Part 2 allocates any of these sites, which may address the Oxford unmet need, or whether other sites are allocated. In any event, there remains the shortfall of the 962 homes required to serve the District’s needs.

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Settlement Hierarchy

2.17 Core Policy 8 of the LP Part 1 identifies the main settlements in the Abingdon and Oxford Fringe Sub-Area as follows:

Market Town: Abingdon-on-Thames

Local Service Centre: Botley

Larger Villages: Cumnor, Drayton, East Hanney, Kennington, Kingston Bagpuize with Southmoor, Marcham, Radley, Sutton Courtney, Steventon and Wootton

2.18 The Officer’s Report to Cabinet (7.8.15) noted the most sustainable larger villages:

Cumnor Kingston Bagpuize with Southmoor Radley Wootton

2.19 Regarding the sustainability of Radley, the Inspector said in his final Report (emphasis added)7:

As a ‘larger’ village with local services, including a station with direct trains to Oxford, Didcot and London, there is little to support the argument that Radley could not appropriately accommodate the 240 or so dwellings envisaged for Site 4.

2.20 The LP Part 1 Inspector also expressed views on likely settlements suitable for sustainable growth in his Interim Report8:

[other villages in the Abingdon and Oxford Fringe Sub-Area] would not be a sustainable location to provide for the majority of the sub-area’s housing requirement, most of which is likely to arise from people currently living in Abingdon, Botley, Radley and Kennington9.

the Abingdon-on-Thames and Oxford Fringe sub-area contains the Vale’s largest settlement (Abingdon) in addition to the local service centre of Botley and a number of larger villages, including Radley and Kennington10.

7 LP Part 1 Inspector’s final Report para 83 8 Inspector’s Interim Findings 7.6.16 9 ditto para 8.2 10 ditto para 8.1

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It is the desirability of providing for housing needs in the Abingdon-on-Thames and Oxford Fringe sub-area, in close proximity to Abingdon and Oxford City, that is fundamental to my conclusion that exceptional circumstances exist to justify removing from the Green Belt the sites [the Part 1 sites] indicated above.11

However, in addition, the plan proposes to delete from the Green Belt some 15 or so other parcels of land at Botley, Chawley, North Hinksey, Cumnor, Wootton and Appleton; land which would not be allocated for any particular use12

it cannot reasonably be argued that deletion of land from the Green Belt at Botley, Cumnor, Wootton and Appleton would be necessary to ensure logical, defendable and permanent Green Belt boundaries at Abingdon, Radley and Kennington13.

I am therefore unconvinced by the confidence expressed by the Council at the hearings that the land proposed to be deleted from the Green Belt at Cumnor, Botley, Appleton and Wootton would be sufficient to provide for the yet to be allocated Vale’s own housing needs14

the exceptional circumstances necessary to justify removing from the Green Belt the parcels of land at Botley, Cumnor, Wootton and Appleton do not exist15

I conclude that the exceptional circumstances necessary to remove Farmoor from the Green Belt do not exist.

several other parcels of land at Abingdon, Kennington and Radley are proposed to be deleted from the Green Belt but not allocated for any purpose. In terms of the land at Abingdon and Kennington I can see some sense in its removal from the Green Belt, in the context of the removal of housing sites 1,2,3 and 4 and the desirability of producing logical and permanent Green Belt boundaries. I also note that there is potential for housing development on the land at Radley, although, as detailed in section 13 below, there is not an identified need for this at the present time16

Given the prospect of a further Green Belt boundary review, permanence of the submitted plan’s Green Belt boundary at Abingdon, Kennington and Radley cannot currently be guaranteed. It would therefore make sense to retain these parcels of land in the Green Belt until either a further Green Belt review has taken place or there is some certainty that such a wider review will not be necessary.17

11 ditto para 8.4 12 ditto para 8.4 13 ditto para 8.5 14 Inspector’s Interim Findings 7.6.16 para 8.8 15 ditto para 8.10 16 ditto para 8.13 17 ditto para 8.13

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Conclusion: Housing numbers and distribution

2.21 Thus, the VWH contribution to unmet Oxford housing need (2,200) and the Sub-Area housing shortfall in Core Policy 8 (962) totals 3,162 homes, and these are in addition to the sites allocated in the Part 1 Plan. The majority are most likely to need accommodation within the Abingdon and Oxford Fringe Sub-Area.

2.22 In this Sub-Area, the ‘market town’ settlement is Abingdon, and the Local Service Centre is Botley. The ‘larger villages’ are Cumnor, Drayton, East Hanney, Kennington, Kingston Bagpuize with Southmoor, Marcham, Radley, Sutton Courtney, Steventon and Wootton. Of these, the “most sustainable larger villages” defined by the Cabinet Report on accommodating extra growth (7.8.15) are Cumnor, Kingston Bagpuize with Southmoor, Radley, Wootton.

2.23 Of these, the Inspector is dismissive of growth/Green Belt releases at Botley, Cumnor, Wootton, and at (smaller villages) Appleton and Farmoor. This leaves Abingdon and Radley as the most sustainable settlements to accommodate further housing growth and Green Belt release in the Abingdon and Oxford Fringe Sub-Area as selected by VWHDC and the Part 1 Local Plan Inspector.

2.24 Moreover, Radley is noted as having “excellent public transport links to Oxford, with a railway station located at Radley” in the Cabinet Report (7.8.15).

2.25 Against this background, it is surprising that the Draft NP merely recognises the LP Part 1 strategic allocation of Radley NW, as well as the other two allocations which, although in Radley Parish, are urban extensions of Abingdon and Kennington. It is Radley as a settlement which is an attractive sustainable location in the Abingdon and Oxford Fringe Sub-Area, not the Parish.

2.26 The Draft NP does identify only two possible housing sites - The Old Coal Yard at Thrupp Lane (in the Green Belt) and the Allotments (in the centre of Radley and owned by RPC) -

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which collectively “could accommodate a further 20-25 homes”18. This seems a tiny contribution from a prime sustainable settlement towards the 3,162 extra homes required by the Local Plan Part 2.

2.27 The assertion that “this document [the Draft NP] assumes that no additional allocations will be made at Radley” in LP Part 2 seems not to be based on any evidence, or indeed the reality of the situation. Indeed, the timing of publication of the Draft NP just before LP2PA in February 2017 is confusing to the public and maybe seeking to unreasonably influence the content of LP2PA. There is no record of collaboration with VWHDC, or any recognition of housing numbers needing to be allocated, contrary to PPG009 (see above). It would have been preferable to at least await the LP2PA in February to see if any new sites are allocated. Better still (because the ‘preferred approach’ is not the last word on the matter) to have awaited the ‘Pre-Submission’ version in October 2017. Clearly, if no additional sites at Radley are proposed in LP2PA, then AWEL (and perhaps others) will be making (and pursuing) an objection roughly based on the foregoing evidence. If additional sites are proposed for allocation, then the RNP will require a complete overhaul making this Consultation Draft redundant.

3.0 SUMMARY OF THE NP CONSULTATION DRAFT PROPOSALS

3.1 There is much to support in the Draft NP, but without a realistic housing allocation which recognises the ‘bigger picture’ some proposals have a doubtful prospect of implementation. Some proposals are labelled ‘PP’ (planning permission) which is decisive, others are CA (Community Action) which can be seen as aspirational.

3.2 The Draft NP proposals are summarised and grouped as follows:

Housing Sites Draft NP ref Draft NP proposal 2 housing sites (the Old Coal Yard and the Allotments) with 4.2.3 p16, PP.1 and PP.2 capacity for 20 - 25 homes the NW Radley site should include a playground PP.7

18 Draft NP p14

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the South Kennington site should include a playground and PP.7 shop site the NW Radley and S Kennington housing sites should provide PP.10 a new doctor’s surgery or make a financial contribution for a new facility elsewhere

Community Facilities ‘re-imagining’ (and possibly replacing) the village hall, CA.3 p23 playground and playing field on the current site retain the community shop on its current site, or relocate on 4.4.3 p23 CA.4 a larger site identify a site for additional allotments and a replacement CA.5 site for existing allotments a cemetery close to the primary school (working with Radley CA.6 College) land around the Bowyer Arms should be identified as an asset PP.6 of community value and a location for community facilities expansion of the Radley primary school on or near its current 4.5.3 p25 CA.7 site expansion of the nursery facilities at Kennington primary CA.8 school

Radley Lakes RPC should produce a masterplan for the proposed Radley 4.6.3 p29 CA.9 Lakes Area of Quiet Recreation and Nature Conservation (in collaboration with landowners, VWHDC, Abingdon on Thames Town Council, local conservation and amenity groups) existing or new industrial or commercial sites, when requiring PP.11 any planning permission, should contribute to safe cycling and walking access to Radley Lakes

New Access Road commercial development on the JCSL industrial estate will be PP.12 supported if a new access route is created to link with Audlett Drive, Abingdon a new road should be provided to connect the industrial and CA.10 commercial sites at the southern end of Thrupp Lane with Audlett Drive, Abingdon - RPC will work with OCC, VWHDC and landowners

Highways and Access new development should support the Radley Roads Strategy 4.7.3 PP.13 and provide for the mitigation of the effects of the development on the road network, either financially or in kind new development should support the Radley Cycling and PP.14 Walking Strategy either by on-site provision or financial contributions RPC will work with other LAs, landowners, developers and PP.15 Sustrans to achieve the Radley Cycling and Walking Strategy a new roundabout junction for Whites Lane, Foxborough 4.7.2 p30 Road and Thrupp Lane

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vehicular access to the strategic housing sites should be 4.9.3 p36 PP.15 ‘outward facing’ onto the main through route, with pedestrian and cycling access ‘inward’ to village facilities

Railway Station restrict on-street parking at Radley Station; extend off-street 4.10.3 p37 CA.12 parking and bike storage; provide step-free access to the up- PP.17 line with a ticket machine, with developer contributions from new strategic sites

Utilities drainage provision requirements on new sites and RPC will PP.17 and PP.18 work with Thames Water to ensure priority is given to maintaining and upgrading the sewerage network improved broadband 4.12.3 CA.14

Green Infrastructure ensure LP policies 44 and 46 (landscape and green 4.13.3 CA.15 infrastructure) are fully respected in all developments RPC should maintain the pond adjacent to the Church for CA wildlife

Funding Part 5 Funding sources: section 106, Community Infrastructure Levy, other contributions, grants, service providers and RPC resources.

3.3 This Report’s Comments on these proposals are as follows.

Housing

3.4 The paucity of the additional housing provision in the Draft NP has already been covered above - Radley to contribute just 25 additional homes when 3,162 extra homes are required, most if not all, in the Abingdon and Oxford Fringe Sub-Area in which Radley is located.

3.5 There are references to items to be included in the Kennington site (which is within Radley Parish), but no mention of the views of Kennington PC.

3.6 There is no supporting evidence that ‘reasonable alternatives’ have been investigated even if a Sustainability Appraisal/SEA is not required (but see relevant PPG above). However, it would be of interest in understanding the value of the Draft NP to see how the modest housing sites were selected and what other sites were considered.

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Community Facilities

3.7 The relocation of the Village Hall and playing field is clearly contentious, and has been an on-going problem since 2008, as recorded on pp 19, 21 of the Draft NP. The existing site is owned by Radley College and leased to RPC. Playing fields to the south are on land owned by clients of AWEL. Radley College proposed a new site (May 2016) north of Church Lane, but this only received 37% approval in response, because “the site would be too far away from where many families live”19. Subsequently, RPC did not support that relocation.

3.8 The Radley South proposals would include a site for replacement facilities on land owned by the clients. This is illustrated at Appendix 1.

3.9 The current proposal is to “re-imagine” (whatever this means) the facilities on the current site (CA.3) but this seems sub-optimal, with no clear idea what it means or how it would be funded. Also, the renewal of the lease and continued availability of the playing field on Radley South cannot be assured.

3.10 The proposal this Report makes, on behalf of AWEL and the landowners, is to offer a new site as set out in the section below: ‘the merits of Radley South’.

Radley Lakes

3.11 This is clearly an imaginative scheme and is supported by this Report; it is a huge project involving many parties. Also, the new access road to Audlett Drive, Abingdon would relieve Thrupp Lane. Clearly, this would be an expensive project and there would be many other calls on funds raised by way of S106 and CIL. However, with only modest housing proposals (the NW Radley strategic site and the Old Coal Yard), that funding would be also modest. Funds derived from the other two strategic sites would surely be directed to Abingdon and Kennington. The additional housing site at Radley South

19 Draft NP p21

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would significantly increase the funding available, which is referred to in the section on ‘merits’ below.

Highways and Access

3.12 This Report supports all the Draft NP’s policies and proposals. The new roundabout junction for Whites Lane, Foxborough Road and Thrupp Lane is especially supported but should be a policy proposal. The Radley NW proposals20 included improvements to this junction, but these are inferior to a roundabout. Radley South could contribute to this improvement, and the saved cost for Radley NW could be spent elsewhere.

Other

3.13 The other policies and proposals - railway station, utilities, green infrastructure and funding sources are all supported by this Report.

4.0 THE CASE FOR RADLEY SOUTH

4.3 NPPF para 14 provides the Government position:

20 Barton Wilmore submissions VWHLP Stage 2 Matter 8 plan no. 4407/204 21 Inspector’s Final Report 30.11.16 para 83

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At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking. For plan-making this means that: • local planning authorities should positively seek opportunities to meet the development needs of their area; • Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: . any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or . specific policies in this Framework indicate development should be restricted.

4.4 The addition of Radley South to the growth proposals of this ‘larger village’ is justified as a substantial planning benefit by reference to the scale of new housing required without any significant and demonstrable adverse impacts. Whist the site is currently Green Belt, it is inevitable that almost any potential site in the Sub-Area would be too.

Green Belt Release

4.5 The version of the Local Plan Part 1 which was submitted to the Secretary of State included proposals for several sites to be released from the Green Belt (in addition to the four that were eventually allocated for development) at Abingdon, Appleton, Botley, Cumnor, Kennington, Radley and Wooton. These are identified in the VWHDC submission to the Examination22. The Inspector did not conclude that there was merit for sites at Botley, Cumnor, Wootton, and at (smaller villages) Appleton and Farmoor.

4.6 The Inspector’s Report rejected the release from the Green Belt of the 18 sites identified in the Submission Plan because no development proposals were made and the ‘exceptional circumstances’ had not been demonstrated. However, he said:

Retaining these parcels of land in the Green Belt now would not prevent their deletion from Green Belt through the ‘Part 2’ plan or any other local plan or local plan review, if the necessary exceptional circumstances were to be demonstrated.23

22 Appendix 3 23 Inspector’s Final Report 30.11.16 para 91

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4.7 That is now the position: Oxford’s unmet housing needs have been calculated which, when added to the existing shortfall, present the grounds for releasing further land (now specifically for housing development). The LP Part1 Inspector’s Report also said24:

However, given the prospect of a further Green Belt boundary review, permanence of the submitted plan’s Green Belt boundary at Abingdon, Kennington and Radley cannot currently be guaranteed. Indeed, there is interest in developing some of this land for housing to assist in contributing towards Oxford city’s unmet housing needs, although this remains a matter for the ‘Part 2’ plan. It would therefore make sense to retain these parcels of land in the Green Belt until either a further Green Belt review has taken place or there is some certainty that such a further review will not be necessary.

4.8 Lastly, the merit of the Radley South site is noted by the Inspector as having “potential for housing development”.25

Impacts

4.9 Radley South was identified for Green Belt release in the Submission version of LP Part1. It was recommended for Green Belt release in the Vale of White Horse District Council/Kirkham Landscape Planning Ltd Green Belt Review Phase 3 Report (February 2014), identified as site 1426. NW Radley (site 16) is now released from the Green Belt. Comments in that Report on the two Radley sites are:

• Key landscape characteristics contributing to the adjacent Green Belt: No significant features.

• The new boundary of Area 14 follows open farm tracks.

• Area 14 is an open landscape. Particular care needs to be taken to enclose the area in substantial tree belt and woodland planting to ensure that any new built form does not have an adverse impact on the open character of the adjacent Green Belt.

• Area 16 is visually exposed and close to Radley Park. Care to be taken that any new built form does not have an adverse impact on the open character

24 ditto para 100 25 Inspector’s Interim Report 7.6.16 para 8.13 26 Appendix 2 Vale of White Horse District Council/Kirkham Landscape Planning Ltd Green Belt Review Phase 3 Report (February 2014) extract

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of the adjacent Green Belt through retention of existing trees and new planting along White’s Lane / Kennington Road.

4.10 There seems little between the sites in terms of impacts, but site 16 (Radley North West) was allocated and Site 14 (Radley South) was not, only on the basis that site 16 could accommodate more than 200 dwellings. Actually, Site 14 (Radley South) with a gross area of some 8.6ha gross, 7.9ha net could accommodate some 230 homes27.

4.11 The site is a natural southern extension to Radley between Thrupp Way and the Oxford railway. It is flat, and peripheral planting would frame and define the extended urban Radley urban area, as recommended by Kirkham. The site is not within any designated or recognised landscape area.

4.12 Access would be via Thrupp Lane suitably improved, connecting to the new roundabout junction for Whites Lane, Foxborough Road and Thrupp Lane28. Pedestrian and cycle access can be provided through the existing residential area as shown in the Concept Plan (Appendix 1).

4.13 There are no other obvious impacts.

Other benefits

4.14 There would be other benefits to offer RPC and the community: a new site to the east of Radley South of a size suitable to relocate and build a new Village Hall, and make provision for pitches, cricket ground, allotments, children’s play area etc. as shown on the Concept Plan (Appendix 1). The availability of the current site for development could enable Radley College to fund the new building and provision of the facilities.

4.15 Additional funding, doubling that from Radley NW, could contribute to items including the Radley Lakes proposal and to education provision. There is also a possibility of land being made available to implement the proposed connection to Audlett Drive.

27 LP Pt1 Core Policy 23 requires a minimum density of 30 dwellings per ha 28 Draft NP para 4.7.2 p30

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Delivery

4.16 The site is in single ownership and obviously deliverable in the short-term. If the allocated NW Radley site were to remain in the Plan and developed in tandem it would be possible to align S106 Agreements to include contributory funding/provision to benefit Radley, rather than a two-stage approach where such arrangements would be disjointed over time. Also, Radley NW may perceive it to be an unfair burden if it had to fund everything knowing that Radley South would later be developed. If the sites were to be developed in tandem, then proper provision could be made from the outset.

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5.0 CONCLUSION

5.1 This Report has been submitted on behalf of AWEL in response to the consultation on the Radley Neighbourhood Plan Consultation Draft December 2016. A copy has also been sent to VWHDC.

5.2 Government Guidance is that the NP and LP should be developed together in harmony, but in Radley’s case the Consultation Draft has been published weeks before the LP Part 2 Preferred Approach is due, making an unsupported assumption that no additional sites will be allocated. There is also no obvious assessment of options before two (small) sites are proposed for development.

5.3 The Draft NP seems to have been developed in a vacuum, despite Radley being one of the most sustainable settlements in the Abingdon and Oxford Fringe Sub Area. There is a housing need to be accommodated of 3,162 extra homes (additional to the LP Part 1 allocations) mainly in the Sub Area, yet the Draft NP is proposing to make a minute contribution of just 20 - 25 homes.

5.4 Radley has been identified as one of the most sustainable settlements in the Sub Area in a Report by VWHDC (7.8.15) and by the LP Part 1 Inspector, because of its local services and rail station connecting it with Oxford and London (30.11.16). There are other settlements defined as ‘larger villages’ but only four (including Radley) are considered ‘most sustainable’ in the 2015 Cabinet Report. Even so, the Inspector is rather dismissive of the other three.

5.5 Except for the paucity of extra homes allocated in the Draft NP, and lack of analysis of alternatives, this GPL Report supports most of the policies and ‘community actions’. Many will require substantial financial contributions which are unlikely to be wrung out of the NW Radley site (approximately 240 homes). Other sites at South Kennington and North Abingdon may be in Radley Parish but any contributions they make could be expected to serve those settlements to which they are attached, not Radley Village.

23 Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

5.6 The Draft NP highlights the dissatisfaction with the existing Village Hall and playing fields. It also has a worthy, but ambitious, strategy for creating ‘Radley Lakes’ and a new access to Audlett Drive, Abingdon. The school and community shop also seek support. These initiatives may founder through lack of funding.

5.7 There is a strong case for allocating Radley South, and not only because of the extra funding it could offer to the community facilities. Further land is required for housing, and Government policy is that local planning should make allocations to serve need unless the impacts are overwhelming.

5.8 Releasing more land from the Green Belt is inevitable to serve the needs of the Sub Area as well as Oxford. This is anticipated in the LP Part 2, and endorsed by the LP Part 1 Inspector’s Report. Radley South is in the Green Belt but the Submission Draft LP Part 1 did support its release. The Inspector supported this should a need be established, which it now has (not least because of Oxford’s needs now being agreed). Landscape impact is unexceptional as assessed in the VWHDC commissioned 2014 Kirkham Report. The site is a natural southern extension to Radley, it is not within any designated or recognised landscape area.

5.9 Vehicle access would be via an improved Thrupp Lane joining the proposed roundabout junction on p30 of the Draft NP. It could make a contribution to those highway works. Strong cycle and pedestrian links can be made to the village core.

5.10 The site is in a single ownership and easy to develop quickly to provide the much-needed housing.

5.11 Owners of Radley South could also provide a new site to its east providing space for a new Village Hall, football pitches, cricket pitch, children’s play area and a carpark. This would be major benefit to the village and resolve the problems with the existing site. If that were to be developed too (owned by Radley College but leased by RPC) then it could fund the works and build the Hall.

24 Radley Neighbourhood Plan, Consultation Draft Gardner Planning on behalf of Arnold White Estates

5.12 If the LP Part 2 does allocate the site (despite the apparent ‘lobbying’ effect of the Draft NP) then the NP will have to be rethought. If it does not, then AWEL will continue the campaign right through the planning process.

5.13 AWEL will continue to seek to work with the Parish Council and the community, but will pursue, in every way possible, the allocation of the site and the recognition of the benefits that could be realised for Radley.

25 Radley Neighbourhood Plan

Consultation Draft December 2016

Response by Arnold White Estates Ltd

Appendix

1. Radley South Concept Plan including relocated Village Hall and pitches.

11 T J 1 AMES T

a 6 75 E t

RR 2 3 o

21 8 A CE 4

1 85 The Bowyer Arms (PH) 75 77 73

3 1 Radley Station

WHITE

' S

L 59 A 28 N

108 6

T 98 4

47 URNE 5

9 0 C

S 5

E 3 1

1 7 6 3

7 Station 78

25 72

ROAD 27 GH 68 OROU

FOXB

64 1 2 B

13 4 6 O 41 W YER

4 ENT SE CRESC NHOU

3 STO

54 BADGERS COPSE

2 13

Hid 0 52

12 6 1 7

co 1

1 1

8 36 Co nifers

Ashbrook

3 4

GO OSEA CR E 1

6 1

3 5

Hall 1 2

NORFOLK CL

6 2 4

DRYSDALE CLOSE

4 1

Village Hall

Car park

Play area

T HRUP Allotments P L

ANE

Conchiglia

Rettford

Goose Acre Farm

T HR

P LA

Pond

Radley South proposed development Proposed boundary planting

Other available land in the same ownership Proposed street trees

Current Village Hall and playing ﬁelds Proposed allotments

Home Farm Proposed playing ﬁelds

Home Farm Barn Proposed open space DRAFTProposed residential Proposed footpath/cycleway

Sustrans Route 5

Arnold White Estates Ltd 1-46_100.A | 30-01-2017 | 1:4,000@A4 built form resource Radley Neighbourhood Plan 0 50 150 Consultation

01865 261456, Oxford Centre for Innovation, New Road, Oxford OX1 1BY [email protected] www.builtformresource.com Radley Neighbourhood Plan

Consultation Draft December 2016

Response by Arnold White Estates Ltd

Appendix

2. Extract from VWHDC/Kirkham Report on Radley South VALE OF WHITE HORSE GREEN BELT REVIEW: PHASE 3 1

VALE OF WHITE HORSE DISTRICT COUNCIL

GREEN BELT REVIEW

PHASE 3 REPORT:

AMENDMENTS TO BOUNDARIES OF THE GREEN BELT AROUND INSET VILLAGES AND NEW INSET VILLAGE AT FARMOOR

1. Scope of the Report

The Phase 2 Report identified a number of locations on the edge of settlements and the settlement at Farmoor to be examined further for a possible revision of the Green Belt boundary. Consequently this Phase 3 report proposes alterations to the boundaries based on the contribution of these edge of settlement areas to the purpose of the Green Belt and its open character (see Phase 2 Report). The boundaries of each area are selected to be identifiable on the ground.

All of the areas are greenfield and open in character at present. A cautious approach has been taken to limit recommendations for the removal of land in the Oxford Green Belt to those areas that are not considered, in the light of the tests set out in Phase 2 Report, to meet the purposes of the Green Belt.

Any future proposals for these areas would also be considered in the light of prevailing economic, social and environmental matters at the time and therefore the usual landscape and visual constraints and opportunities on the land would still apply. Where a key landscape or visual feature of the area is important to the functioning of the adjoining Green Belt, this is specifically referred to in the supporting text.

The Report presents a series of plans, one for each settlement, showing proposed changes to the Green Belt boundary, accompanied by notes on the revised boundaries. Encircled numbers refer to notes in the Phase 2 Report Table 4.

It is recommended that two areas noted in the Phase 2 Report, at Botley (North Hinksey) (Area 12) and Abingdon (Area 15), remain within the Green Belt following the detailed assessment. In both cases the areas were considered to contribute to the purposes of the Green Belt.

VALE OF WHITE HORSE FEBRUARY 2014 KIRKHAM LANDSCAPE PLANNING LTD

VALE OF WHITE HORSE GREEN BELT REVIEW: PHASE 3 8

RADLEY: PROPOSED CHANGES

Proposed revised boundaries The boundaries at Radley have been revised in two areas. The new boundary of Area 14 follows open farm tracks. The boundaries of Area 16 follow White’s Lane and Kennington Road. Key landscape characteristics contributing to the adjacent Green Belt No significant features Other comments Area 14 is an open landscape. Particular care needs to be taken to enclose the area in substantial tree belt and woodland planting to ensure that any new built form does not have an adverse impact on the open character of the adjacent Green Belt. Area 16 is visually exposed and close to Radley Park. Care to be taken that any new built form does not have an adverse impact on the open character of the adjacent Green Belt through retention of existing trees and new planting along White’s Lane / Kennington Road.

VALE OF WHITE HORSE FEBRUARY 2014 KIRKHAM LANDSCAPE PLANNING LTD

Radley Neighbourhood Plan

Consultation Draft December 2016

Response by Arnold White Estates Ltd

Appendix

3. VWHDC submission on Green Belt sites to LP Part 1 Examination and Adopted Sub- Area Plan VALE OF WHITE HORSE DISTRICT COUNCIL

LOCAL PLAN PART 1 EXAMINATION HEARING

SUMMARY NOTE ON CHANGES

TO THE OXFORD GREEN BELT

______

VoWHDC SUMMARY BULLET POINTS

______

1. At the Vale of White Horse Local Plan Part 1 Examination Hearing Sessions for Matter 1 and Matter 4 from Tuesday 22 September 2015 to Wednesday 23 September 2015 matters relating to the Oxford Green Belt were discussed.

2. The Inspector has asked the Vale of White Horse District Council to provide a note which identifies the sites proposed for release from the Green Belt. In acknowledgement of these concerns, the Council has prepared this note.

3. Changes to the Oxford Green Belt boundary are listed in Table 1. A visual representation of the sites released from the Green Belt is set out in Appendix A.

Table 1 – Sites recommended for release from the Oxford Green Belt in the Vale

Size of land Settlement Land Parcel Sub-Area parcel (ha)

Botley A 8.18 Abingdon and Oxford-Fringe B 1.92 C 10.79 D 3.45 Cumnor E 9.19 F 8.89 G 9.54 H 5.48 I 6.79 Appleton J 5.35 K 3.42 Wootton L 4.62 M 10.95 N 7.91 Kennington O 2.2 P 7.17 Q 31.08 Radley R 13.84 S 10.57 Abingdon T 1.88 U 17.64 V 15.56 W 14.91 X 32.39 Appendix A: Vale of White Horse District Green Belt Location Map Sites proposed for release from the Oxford Green Belt ±

Swinford Wytham

Farmoor !A

!B Botley !D !E !F !C !G !H South Hinksey Cumnor !I Eaton !O

Boars Hill Kennington !J !K !L !P Appleton Wootton !N !M Sunningwell !Q

!W !V Cothill !U !R !X Radley Shippon T ! !S Abingdon Proposed sites for release Frilford Green Belt Marcham

Figure 5.1: Abingdon-on-Thames and Oxford Fringe Sub-Area

61 Vale of White Horse Local Plan 2031 Part 1 – December 2016