South Oxfordshire District Council by Email

County Hall New Road Oxford OX1 1ND

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

26 January 2018 Copy: [email protected]

Dear Sir/Madam

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

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

Watlington is one of the larger villages in South Oxfordshire. The South Oxfordshire Proposed Submission Local Plan calculates that there is a need to allocate land for approximately 260 houses in Watlington on the basis of achieving a target of 15% growth between 2011 and 2033 as follows (taken from p66 of Proposed Submission Local Plan):

Larger village Core Strategy Completions & Outstanding Target for + 15% growth Commitments NDP Watlington 262 28 234 260

The Plan proposes to allocate land for at least 238 houses as follows: 1. A – Land between Britwell Road and Cuxham Road – 140 2. B – Land off Cuxham Road and Willow Close – 38-60 3. C – Land off Pyrton Lane – 60

The above sites are along the alignment of a proposed new ‘edge road’.

In respect of the above, a planning application has been lodged on A - P17/S3231/O – for 183 dwellings and 650m2 of business class B1a (this is hybrid application with full permission sought for the dwellings). The County Council lodged a transport objection to that application on 1 December 2017. There has also been a planning application in respect of land to the east in Pyrton Parish P16/S2576/O, for 100 residential dwellings, to which the County Council lodged an objection in October 2016.

The sites and the alignment of the new edge road are shown on the map below (taken from the Submitted Neighbourhood Plan):

The Proposed Submission Local Plan Second Preferred Options also contains a proposal to safeguard land for a Watlington Bypass shown on the map below (page 227 of Proposed Submission Local Plan).

Yours sincerely

L Hughes

Lynette Hughes Senior Planning Officer Email: [email protected] 2

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

Education

Land to Expand the Primary School and Secondary School

Amend Policy P8 (Physical and Social Infrastructure) along the following lines:

Development will be encouraged which contributes to: … (c) The provision of land to safeguard for possible future expansion of the primary and/or secondary schools (d) The provision of new and/or expanded facilities for early education and childcare. …

Amend Watlington Housing Policy: Site C along the following lines: … The Planning Proposals prepared for this site should demonstrate how the proposed development: … Provides land to be safeguarded for future expansion of the schools if this is not available elsewhere Is able to proceed following a resolution of issues concerning the potential need for expanding the primary school and/or secondary school onto this site ….

Summary

1. The 238 new homes proposed for Watlington in this Plan would be expected to generate in the region of 12 children qualifying for free nursery education (under current statutory entitlement), 60 primary pupils and 45 secondary pupils, assuming a housing mix in line with the existing SODC Core Strategy policies.

2. The Plan recognises that land may be needed for school expansion due to uncertainties about population growth in Watlington and the wider area.

3. Policy P8 (page 39) encourages development which contributes to (c) the provision of land to safeguard for possible future expansion of the primary and/or secondary schools and (d) the provision of new and/or expanded facilities for early education and childcare. This is welcomed. A suggestion is made to delete the reference to safeguarding in this policy and the site policy as reference to ‘safeguarding’ appears redundant and potentially confusing.

4. To provide for both an expansion of the primary school and the secondary school, all of Site C (an area of 4.6ha) might be required. This is because the primary school

would need to expand by 0.4ha and the secondary school would need to expand by up to 4.4ha.

5. The primary school’s current site, while sufficient for its current size of 1.5 form entry, would need to be extended if the school needs to expand to 2 form entry. The future size and location of Icknield Community College cannot be confirmed until a decision is reached on the Chalgrove Airfield development, but, should the school need to expand additional site area would be required. In addition to primary and secondary school capacity, additional early education and child care provision will also be required to meet the extra demand created by the development proposed in this Plan. In these circumstances, it must be a requirement that land to expand the schools is provided at Site C unless some alternative arrangement is agreed.

Detailed comments

Primary School

6. Watlington Primary School is a 1.5 form entry school, admitting up to 45 children per year and with a total capacity of 315 places (excluding the nursery). As of September 2017 the school has 257 children on roll, with spaces in nearly all year groups (although numbers fluctuate and some year groups have only few spare places) i.e. 58 spare places in total. At this moment, it therefore has close to sufficient capacity to meet the expected needs of the proposed scale of development. However, inevitably, there is uncertainty over future birth rates and housing development, and protecting the ability of the school to expand is a sensible precaution.

7. Expansion of the school to 2 forms of entry (60 children per year, total capacity of 420 places) would offer benefits to school financial and organisational management. However, to sustain pupil numbers at 2 form entry level, more housing growth than that currently proposed would be necessary.

8. The school’s current site area of approximately 1.8ha is below the county council’s standards for a 2 form entry school, but the site adjoins that of Icknield Community College, and also the proposed development referred to in the Plan as site C. The Housing Policy regarding site C (page 51) requires that the development “provides land to be safeguarded for the future expansion of the schools if this is not available elsewhere”. It would need to be the county council which determines whether such expansion land is required, at the time that any planning application is submitted.

Secondary School

9. Icknield Community College is a 5 form entry 11-16 school, admitting up to 140 children per year and with a total capacity of 700 places. As of September 2017 the school has 664 children on roll, and is experiencing rapid growth in pupil numbers.

10. It currently, therefore, has only 36 spare places, less than the expected pupil generation from the proposed scale of housing growth within the Watlington Neighbourhood Plan. However, this number of spare places is expected to fall over the coming years, and based on recent trends the school would be expected to quickly fill. Moreover, the school serves a large designated (catchment) area, shown below, and will also be affected by the significant scale of development underway and 4

proposed at neighbouring settlements such as Benson and Chinnor. The school does not have sufficient current capacity to meet the cumulative needs of development within its designated area.

11. It is therefore necessary to ensure the ability of Icknield Community College to expand in future years is protected through this Plan. The Housing Policy regarding site C (page 51) therefore requires that the development “provides land to be safeguarded for the future expansion of the schools if this is not available elsewhere”. It would need to be the county council which determines whether such expansion land is required, at the time that any planning application is submitted.

12. The future size of Icknield Community College needs to be considered in the context of the large-scale growth proposed in the recent SODC Local Plan consultation for Chalgrove Airfield, which lies within the school’s designated area. Approximately 3,000 homes are being considered here.

13. The proposed Chalgrove Airfield development, in isolation, would not make a new secondary school sustainable without threatening the viability of Icknield Community College.

14. The combined impact of all the currently proposed scale of growth, in addition to the existing population, within Icknield’s designated area would be expected to require a secondary school of around 1500 places. The county council’s requirement, based on government guidelines, would be a site of 10.6ha for a 1500-place school.

15. Icknield Community College’s current site area is approximately 6.2ha. Based on government guidelines, this is sufficient for 800-1000 pupils, i.e. 200-400 more than the current roll, and could therefore support some expansion of the school. This would not, however, be sufficient to meet the needs of the proposed Chalgrove Airfield as well as the permitted/planned/proposed growth within Icknield’s designated area. (It would be expected to be sufficient excluding Chalgrove Airfield.)

16. If the proposed Chalgrove Airfield allocation is approved, a strategic solution will be necessary to provide secondary education across the area. This will require a larger site area being made available to Icknield Community College. To bring the current site area up to the standard requirement for a 1500 place school would require an additional 4.4ha being added to the current site.

17. The school’s site is bounded by Watlington Primary School, the proposed development site referred to in the Plan as site C, and land in Pyrton parish. One option for expanding the school would therefore be for land within site C, or in Pryton, to be transferred to the school. However, it may not be possible to provide sufficient additional land.

18. Early discussions have been held into the possibility of a more ambitious strategic approach to secondary school provision in this area. This would be for the existing Icknield Community College to be relocated to Chalgrove Airfield, to enable it to expand. This would bring benefits to the financial sustainability of the school, and enable it to widen its curriculum offer, most notably by extending its age range to include sixth form education, which is not viable at the school’s current size. It would also enable complete replacement of the school’s accommodation. 5

19. To fund the relocation and expansion of Icknield Community College, it would be necessary for the existing Icknield Community College site to be disposed of for development, and the resulting disposal receipt invested in the school’s new accommodation. As noted above, some of the site could be transferred to Watlington Primary School, to protect its ability to expand if necessary.

20. Until the distribution of housing growth is confirmed through the SODC Local Plan process, it cannot be confirmed that the relocation of Icknield Community College would be either necessary or viable. At this stage, therefore, the Neighbourhood Plan needs to protect the ability of Icknield Community College to expand either onto neighbouring land, or through relocation of the school.

Transport

Amend Policy P2 (Transport) along the following lines:

(a) Proposals for development on allocated sites to the north and west of Watlington will be required to identify land for a safeguarded route for a re-aligned B4009 in accordance with the indicative route. (See Figure 9) will need to demonstrate how a new road in accordance with any safeguarded route in the Local Plan and as identified in this Neighbourhood Plan will be constructed.

(b) Development which will have significant impacts on the transport network will be refused permission unless it can be demonstrated that improvements within the network can be undertaken to limit those impacts.

(c) Proposals for development are expected to demonstrate how they will minimise air pollution caused by vehicle emissions, particularly in the cumulative effect within the designated Air Quality Management Area arising from extra traffic generated by new development. (See figure 4 )

(d) Traffic management strategies to enhance the centre of the town will be detailed through the Watlington Traffic Management Plan.

(e) Sites for public parking will be encouraged within or adjoining the built form of the town in order to relieve pressure on existing provision.

Amend Watlington Housing Policy: Site A along the following lines: … The Planning Proposals prepared for this site should demonstrate how the proposed development: … • Provides land to safeguard a route for a re-aligned B4009 for a new edge road in accordance with any safeguarded route in the Local Plan and as identified in this Neighbourhood Plan • Deals satisfactorily with adverse traffic effects in advance of a new edge road being constructed in its entirety • Provides connectivity within the site and with the town and countryside 6

• Contributes suitable traffic calming measures on Britwell Road and Cuxham Road as agreed with OCC. …

Amend Watlington Housing Policy: Site B along the following lines: … The Planning Proposals prepared for this site should demonstrate how the proposed development: … • Provides land to safeguard a route for a re-aligned B4009 for a new edge road in accordance with any safeguarded route in the Local Plan and as identified in this Neighbourhood Plan • Deals satisfactorily with adverse traffic effects in advance of a new edge road being constructed in its entirety ….

Amend Watlington Housing Policy: Site C along the following lines: … The Planning Proposals prepared for this site should demonstrate how the proposed development: … • Provides land to safeguard a route for a re-aligned B4009 for a new edge road in accordance with any safeguarded route in the Local Plan and as identified in this Neighbourhood Plan • Deals satisfactorily with adverse traffic effects in advance of a new edge road being constructed in its entirety ….

Amend terminology and clarify references to new edge road

References within the neighbourhood plan to a ‘realignment of the B4009’ should be replaced with terminology which more clearly describes that what is proposed is an entire new road. ‘New edge road’ is the terminology used in this response.

A new edge road is proposed for safeguarding in the Local Plan but it appears that safeguarding of the route is not proposed through this Neighbourhood Plan. Amendments should be made to clarify the status of the indicative alignment shown in the Neighbourhood Plan.

Summary

21. The County Council has commented on the proposed safeguarding of a new edge road at Watlington in its comments on the South Oxfordshire Proposed Submission Local Plan. Excerpts from the County response are appended to this response. The County Council seeks that these matters be resolved through the Local Plan process, and that the status of the Neighbourhood Plan in relation to the safeguarding be made clear.

22. The County Council’s principal transport concern is to ensure that the allocations do not result in severe traffic effects. It is not clear whether each individual allocation will be deliverable in advance of a new edge road being built. The proposed road is not a County Council scheme.

23. Any policy on transport in a Neighbourhood Plan needs to be carefully worded to ensure that it is not contrary to the NPPF or strategic policies in the Local Plan.

Detailed Comments

New Edge Road

24. The Neighbourhood Plan group’s aspiration for a new edge road is understood. The proposal is the subject of ongoing discussion and research with County Council officers and other interested parties.

25. The draft Neighbourhood Plan, which we commented on in June 2017, indicated that planning permissions for development should not be granted prior to the strategy, funding, plans and timetable for the new edge road being agreed. Such a restriction is no longer proposed. In its absence, it is important that the policies indicate that transport effects will be addressed. Policy P2(b) appears to recognise that development may not be possible in advance of the edge road being agreed. It may be that the County Council will object to development on these sites, as it has done in respect of Site A, P17/S3231/O, where transport effects pending a new edge road are not adequately addressed.

26. We note that 6.7 of the Submission Neighbourhood Plan refers to the emerging Pyrton Neighbourhood Plan. The proposal for a new edge road involves land within Pyrton parish – it is not solely a Watlington Neighbourhood Plan issue. We trust that this cross-boundary matter will be considered by the Examiner. We consider that if the Watlington Neighbourhood Plan is recommended for referendum that residents in Pyrton Parish should be able to vote.

27. We are aware that a new edge road would have wider effects than just Watlington and Pyrton. We expect that the Examiner will consider whether this is already addressed through the Local Plan consultation, or whether, if recommended for referendum, residents from a wider area should be able to vote.

28. We set out in our response on the draft Plan matters that require resolution in relation to the edge road. A summary is listed below: a. The design standards for the new edge road to become the new B4009. The County Council has provided advice on this. b. Funding. The Chalgrove Airfield developer has indicated, in a letter on its website dated in August 2017, that it would be prepared to part-fund the road. Such funding depends on its proposals for development proceeding. There are ongoing discussions with the developers of the sites proposed for allocation in this neighbourhood plan and the Chalgrove Airfield developer. c. CIL compliance. The County Council can only require contributions which meet regulatory tests in respect of being necessary, directly related to the development, and fairly and reasonably related in scale and kind to the

development. It may be that agreements outside of the planning process are required to facilitate the new edge road. d. Connections. It is essential that the separate elements of the road link up between the development sites and that there are suitable junctions at either end connecting to the existing road network.

29. In addition to the above, we note that the neighbourhood plan refers to the likely need to close Pyrton Lane to through traffic if a new edge road is built. Further information on this will be required to assess the potential for making orders to achieve such a closure. It would not be appropriate to have a policy in the neighbourhood plan on this.

Watlington Traffic Management Plan

30. We acknowledge that a Traffic Management Plan has been prepared, dated October 2017, to sit alongside the Neighbourhood Plan. This deals with the introduction of traffic control measures to improve congestion within the town centre; the impact of these measures if a new edge road is built; key issues for the Neighbourhood Plan; and improving pedestrian connectivity.

31. Traffic control measures proposed include: a. Construction of chicanes b. Re-arrangement of existing parking bays on street c. Pedestrian build-outs along existing parking bays and a pedestrian crossing d. Additional traffic signals e. Improving existing speed cushions f. 20mph speed limit g. Traffic Regulation Order for no entry to High Street except for access

32. There is useful information in the Traffic Management Plan about indicative costs of the traffic control measures and examples of their use elsewhere. Further public realm improvements for the town centre are also suggested if and when an edge road is built.

33. Further discussion with the County Council will be needed to consider the proposals in the Traffic Management Plan. Some of the proposed improvements, such as a 20mph limit through the town and traffic calming measures, would need approval from the County Council as Highway Authority and be subject to statutory processes. It is likely that some form of traffic calming in the centre of Watlington would help to encourage drivers to use a re-aligned B4009, but it would need to be carefully designed so as to avoid exacerbating congestion and/or air pollution.

Public Car Parking

34. Policy P2 Transport (e) refers to encouraging more sites for public parking. We recommend deletion of this part of this part of the policy as it is not clearly evidenced. More sites for public car parking could lead to increased car usage. This will not be beneficial to Watlington as a whole, in particular in air quality terms. If possible the focus should be on reducing car usage rather than implementing measures that might 9

increase it. The text on page 32 mentions there is not enough parking ‘to meet the needs of local residents, visitors and people who come into the town to work.’ As Watlington is a relatively compact town for many, it may be possible to travel on foot or bicycle, for local journeys. The promotion of walking and cycling for local trips is essential alongside plans to manage parking in Watlington.

Public Transport

35. We are not seeking a specific amendment to the Neighbourhood Plan in respect of public transport, although references to it are currently limited. This is because the matter should be addressed through policies in the Local Plan and NPPF. Contributions towards ‘pump-priming’ bus service enhancements are likely to be sought by the County Council from development at allocated sites should they come forward. Pump-priming is used to help bus services get to a point where they operate commercially and can therefore continue once the period of funding ceases.

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

BENSON, STADHAMPTON AND WATLINGTON BYPASSES

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

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

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

EVALUATION OF TRANSPORT IMPACTS

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

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

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

Para 107 In particular, the delivery of proposed bypasses for Watlington, Stadhampton and Benson are extremely complex, involving a number of different development sites and landowners and will require the co-ordination of a number of different stakeholders. At this point in time, it has not been satisfactorily demonstrated to the County Council that these pieces of infrastructure can be delivered. Delivery of Stadhampton bypass, in particular, is of major concern. With Watlington and Benson, although there will be delivery challenges, sites are proposed to be allocated along the alignment of the proposed bypasses in neighbourhood plans to help pay for them. This is not the case for Stadhampton. The schemes are seen as very much development specific and do not have strategic importance. The County Council will not be held liable for delivering these routes and costs associated. Given the requirement for third party land, a robust business case would be required to ensure delivery, potentially via a compulsory purchase order.

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

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

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

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

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

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

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

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

impacts on other roads and settlements in the area. This needs to take place before OCC can support a strategic allocation at Chalgrove Airfield.

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

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

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

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

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

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

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