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Mayfield House 256 Road Mr C Hargreaves OX2 7DE Planning Policy Team T: 01865 511444 West District Council F: 01865 404433 Elmfield New Yatt Your ref: Our ref: LP/csw/1070573 OX

By email

7th May 2015

Dear Mr Hargreaves,

WEST OXFORDSHIRE LOCAL PLAN 2031

We write in response to the publication of the submission draft of the Local Plan 2031 on behalf of our client, Mr Nicholas Mills.

Local Plan 2031

We note that the Council is not currently preparing to meet the Objectively Assessed Need identified in the Oxfordshire Strategic Housing Market Assessment (SHMA) 2014. We believe that the Local Plan should aim to meet the full objectively assessed need, to be compliant with national policy.

We support the provision made in Policy H1 of the Local Plan which identifies that 800 homes will be provided in the Burford - sub area. This should be a minimum figure. To assist in meeting the full OAN, the level of housing provided in the Burford-Charlbury sub area could be increased.

We note that this allocation will be made up of existing commitments, sites identified in the Strategic Housing Land Availability Assessment (SHLAA) and windfall development. Table 9.5 of the Plan identifies that in the sub-area, 132 homes have already been completed and that there are existing planning commitments to provide a further 189 units. This leaves an outstanding requirement for approximately 480 dwellings in this sub area over the plan period.

Paragraph 9.6.30 states that additional housing development;

‘will be focused primarily at Burford and Charlbury as designated rural service centres.’

As a designated rural service centre, Burford offers a wide range of shops, services and community facilities. Bus services connect the town to Witney and Woodstock and to Oxford and . The town benefits from a cottage hospital, a primary school, shops, a garden centre, banks and a small supermarket. As such we support the Council’s assertion that it is a sustainable location in which to focus housing growth.

Paragraph 9.6.4 of the Plan notes that there have been no sites allocated for residential development in Burford since the 1980s and that the environmental quality of the town makes it a desirable place to live but restricts the availability of new sites for housing.

Strategic Housing Land Availability Assessment

The West Oxfordshire District Council’s Strategic Housing Land Availability Assessment (SHLAA, 2014) forms an important part of the evidence base for the Local Plan as it helps to demonstrate whether the Council has a sufficient supply of deliverable and developable housing sites to meet its housing requirement.

The SHLAA identifies sites which are capable of delivering 10 or more dwellings, are not located in the functional flood plain, are adjacent to an existing SHLAA settlement and are not constrained by a national or European designation.

Paragraph 5.32 of the Plan anticipates that the sites identified in the SHLAA;

‘will make a significant contribution towards the overall housing target.’

The SHLAA 2014 identifies 8 sites in Burford. Of these, it notes that 5 are not suitable for a range of reasons, largely relating to the potential incursion they would cause into the countryside and to issues with access to those sites. There are three remaining sites in the SHLAA in Burford which are identified as developable.

Burford Cottage Hospital

Burford Cottage Hospital is identified as being developable within an 11-15 year timeframe. Although suitable for conversion to residential use, it is currently still in active health care use and therefore does not represent a realistic option for delivery of housing in the short to medium term.

Site Ref 160 – Tanner’s Lane, Burford

This site is assessed as being suitable and available. It is likely to be achievable although the SHLAA notes that access represents a potential constraint to development. This site is in our client’s ownership and the issue of access is being discussed with the local highways authority, Oxfordshire County Council and with West Oxfordshire District Council. We confirm the suitability, availability and achievability of this site to deliver up to 10 units within a 0-5 year timeframe.

Site Ref 161a – Sheep Street, Burford

This site is identified as being suitable and achievable but not available. This site is also in our client’s ownership and we would like the Council to note that this site is available for development and we respectfully request that the Council amends Appendix I – the Site Assessment Summary of the SHLAA to this effect, to show that Site Ref 161a is developable, within a 0-5 year timeframe.

The site is not only developable, it also represents a highly sustainable location for much needed development in Burford. The centre of the site is located approximately 500m from the centre of the town, within walking and cycling distance of a wide range of shops and services and within 480m of the primary school. Vehicular access is possible off Sheep Street.

We note that the SHLAA identifies that the site has potential to deliver a reduced scale of development to mitigate the impact of the development and that 25 dwellings would be appropriate on the site.

The site covers an area of 6.71 acres or 2.7 hectares. Paragraph 2.21 of the SHLAA has assumed an average density of residential development of 30 dwellings per hectare. By the Council’s calculations, this site could therefore in theory deliver approximately 80 dwellings. Allowing for landscaping to provide a buffer between the new development and existing residential development, and assuming that landscape buffers are required to minimise the impact on the Cotswold Area of Outstanding Natural Beauty, the site in our view has the capacity to deliver in excess of 40 dwellings, even allowing a generous proportion of the area for appropriate open space and landscaping.

WEST OXFORDSHIRE LOCAL PLAN 2031 Page 2 of 3

Such an allocation could make a significant contribution to the Council’s intended aim of focusing development in this sub area in Burford, in a highly sustainable location due to its proximity to the town centre. It would also provide much needed affordable housing – a strategic priority for WODC.

Summary

The allocation of at least 800 homes to the Burford – Charlbury sub area in the Local Plan is supported. This results in a net housing requirement over the plan period of approximately 480 dwellings in the sub-area, much of which the Council intends should be focused in the two rural service centres, Burford and Charlbury. These settlements provide sustainable locations for new housing as they have a good range of shops and services and public transport connections to larger towns.

In Burford, no sites have been allocated for residential development since the 1980s and the environmental quality of the area has restricted the availability of sites. The Council has identified a number of sites which could potentially deliver housing development but has discounted 5 of these sites in the SHLAA.

Of the remaining three sites, Burford Cottage Hospital is unlikely to deliver any new housing until later in the plan period. The remaining two sites, Ref 160 and 161a are in the ownership of our client. Both sites are suitable, available and achievable and we request that Appendix 1 of the SHLAA is updated to more accurately reflect that Site 161a – Sheep Street is available and developable.

Even with the provision of landscape buffers and open space on the site, Site 161a – Sheep Street could deliver approximately 40 dwellings. Site Ref 160 – Tanner’s Lane also has the capacity to deliver approximately 10 dwellings. Together, the sites have the ability to make a significant contribution to the District’s housing needs, in a sustainable location, and in accordance with the Council’s emerging strategy and evidence base.

Please do not hesitate to contact me if wish to discuss this matter any further, or if you require additional information.

Kind regards,

Lois Partridge MRTPI Senior Planner

E: [email protected] T: 01865 404411 M: 07919 303731

WEST OXFORDSHIRE LOCAL PLAN 2031 Page 3 of 3