JPPC ref: DB/6596 Planning Policy Team South Oxfordshire District Council SUBMITTED VIA ELECTRONIC MEANS [email protected] 23rd March 2018 Dear Sirs RE: Baldons Neighbourhood Plan – Final Publication Stage Thank you for the opportunity to comment on the Baldons Neighbourhood Plan (BNDP). We write to make comments on behalf of our client the David R. Young family who own land in the village, notably adjacent to St Peters Church, referenced as site 26-MB in the plan. We applaud the endeavour of the Baldons community in preparing their plan and particularly welcome the laudable aspiration of the document to enhance the village and community through positive development. While supportive of the BNDP’s principles we are concerned by shortcomings in the evidence base, and the apparent disconnect between the plan aspirations and proposed site allocations which represent missed opportunities. With regard to the evidence base we are particularly concerned by the overlooking of sustainable transport connections in the village. The premium bus route between Oxford and Reading, via Wallingford passes immediately adjacent to the plan area and is one of the best services in the district. The basic conditions statement incorrectly states there are no stops in the plan area, this is incorrect as the stop at Golden Balls Roundabout is within it. More fundamentally we believe it is incorrect to overlook such a key public transport route solely because it does not pass directly through the plan area. It is proximate to the settlements and plays a significant role in the sustainability of Marsh Baldon in particular with two stops close by in Nuneham Courtenay. The route is accessible on foot with its attractiveness further enhanced by the provision of bicycle parking at the junction of Baldon Lane which is well used. Cont… The bus service represents a key asset in the sustainability of the settlements. We consider failure to afford any consideration to this route, particularly in the assessment of site allocations, means the plan cannot satisfy the basic condition to contribute to the achievement of sustainable development. The overlooking of the main sustainable transport route for the plan area also means the document does not have regard to national policy and guidance. In particular the BNDP does not exploit opportunities for sustainable transport by locating development where practical to “give priority to pedestrian and cycle movements, and have access to high quality public transport facilities”, as required under paragraph 35 of the National Planning Policy Framework (NPPF). The omission also means the BNDP cannot fulfil the NPPF’s requirement for good design which includes a requirement to optimise potential to support local transport networks (paragraph 58). We are also concerned by inconsistencies in the appraisal of sites, and the resulting site allocations. One of the key objectives of Neighbourhood Planning is that the policies, which would include those for allocation, would be deliverable (paragraph Paragraph: 005 Reference ID: 41-005-20140306 of the PPG refers). The plan seeks to allocate sites upon which planning permission has recently been refused (09-TB and 15-MB) both of which were assessed against the current South Oxfordshire Core Strategy and Local Plan with which the BNDP must be in conformity. A further site (08-TB) was refused planning permission, and subsequently dismissed at appeal in 2002. The inclusion of sites which have been subject of significant opposition and refused planning permission in the recent past risks undermining the BNDP as there is likelihood development will not progress on those sites. The sites have been subject of detailed assessment through planning applications and found to be harmful to the area, it is therefore questionable whether they are appropriate for inclusion in the plan. We are also concerned that the plan has failed to consider sites rationally and therefore does not comply with national guidance (Paragraph: 042 Reference ID: 41-042- 20170728 on the PPG). As earlier noted the appraisal process has overlooked a main asset in the sustainability of the settlement (local bus services). The appraisal also appears to show inconsistency in rating similar sites quite differently, while the development strategy directs a significant proportion of development to a remote part of the plan area. Development in Little Baldon is unlikely to improve the quality of life for other Baldon villagers and would make new residents wholly reliant on the private car adding to traffic in the Baldons for trips to the school and pub in the event they use village services. The remoteness from Toot and Marsh Baldon means there is a likelihood residents would look to services outside the Baldons community given the need for car travel. Housing allocated in Little Baldon also therefore risks not being allowed to go ahead given its poor rating. What is more the sites in Little Baldon appear to be the largest of all the sites, yet they perform the worst. This does not seem to be to be sound planning, and does not have sustainable development at its heart which should be the goal of all forms of planning policy as advised in the National Planning Policy Framework, which appear to govern the Neighbourhood Plan. 2 The proposed allocations also appear to fail the basic tests of conformity with the Local Plan and the NPPF. Little Baldon is not recognised as a settlement in the Local Plan, instead being viewed as open countryside where the construction of new homes is opposed in principle. The allocation of new homes in the area cannot be said to meet the basic condition of conformity with the development plan for the area. Furthermore, despite the assertions of the Basic Conditions Statement the allocated sites do not seem to fulfil any of the criteria to be considered appropriate development in the Green Belt. Sites 23-LB and 24-LB are presently in agricultural use, they are not therefore previously developed land within the meaning of the NPPF. Equally neither site could be said to be an infill development with 24-LB only loosely related to buildings on 1.5 sides, and 23-LB with no surrounding buildings at all. Residential development on both sites would be inappropriate development harmful to the openness of the green belt contrary to the NPPF. The Neighbourhood Plan seeks to deliver beneficial outcomes for the area in its pursuit of sustainable development, however we consider the proposed allocations forfeit the opportunity to provide benefits beyond new homes. Our clients own the parcel of land known as Church Field, which lies at the entrance to Marsh Baldon referred to as site 26-MB in the BNDP. We consider the site outperforms many of the selected sites, and would be likely to offer substantial local benefits. Church Field would seem to be to be wholly suitable for 3-4 small dwellings perhaps in a terrace, which would seem to meet many of the other policy objectives set out in the NP. Developing this site could lead to village enhancements that would not otherwise occur. A development upon the site would be excellently placed in relation to key village services, including the Seven Stars pub and the primary school. It would also benefit from being in easy reach of bus services at Nuneham Courtenay. As part of a sensitive development of the site to provide these smaller village friendly homes our client would also envisage further benefits for the village which would be likely to include improved access to the church, both by pedestrians and by car. At present the church has no parking, only by grace and favour of the owners, which may not always be the case. Pedestrians have to undertake a circuitous trip to the church via the road and back on themselves to the church gate. Providing a new access to the site for housing would be likely to mean that pedestrian access could be made direct from the road to the church- we would be pleased to discuss this opportunity, however an illustrative plan showing what could be achieved is shown at the foot of this letter. Provision of parking for the church could also form part of a scheme, this would not only serve the church, but owing to the close location to the heart of Marsh Baldon it could also help to reduce parking pressure around the Green, another aspiration of the plan. Our clients do not make full use of their tennis court, which lies behind the Church Field. If development were to take place on the Field then it would make the court a little more remote from the house, however it may be that wider village use of the court could be made possible so that more people could enjoy it. Access to the court would be possible via the public path that already runs close to it. The provision of an additional leisure facility would clearly be beneficial to the village. 3 The site is in the Marsh Baldon Conservation Area, however this should not preclude development. A sensitive development should not cause undue harm, a matter accepted by allocations elsewhere in the plan. Having reviewed the submitted plan and supporting documents, including the sustainability appraisal, we consider our client’s site represents a much better development for the area and community than several of the proposed allocations. We urge you to reconsider the plan. A new site like this could make a valuable contribution to providing housing within the village in a way which is not likely to cause harm that is already known from existing refused development sites that are included, and would thus meet all relevant policies of the BNDP as well as South Oxfordshire Local Plan and national policies.