Planning Policy South Oxfordshire District Council 135 Eastern Avenue Milton Park Abingdon OX14 4SB 28 January 2018 Our Reference: 254201 Sent via email: [email protected] Dear Sir / Madam, Representations submitted in response to the Submission Version of the Watlington Neighbourhood Development Plan 2017-2033, dated October 2017 On behalf of Pyrton Manor and The Beechwood Estates Company Ltd, I am pleased to set out below representations in response to the Submission Version of the Watlington Neighbourhood Development Plan (WNP). These representations are to be read in conjunction with the enclosed representations from Entran on highways matters. Our clients have significant land and housing interests not only in Watlington but also the adjoining parishes of Pyrton and Shirburn and are therefore key stakeholders that will be affected by any proposals within the WNP. Pyrton Manor and its grounds are located immediately off Pyrton Lane to the north east of the parish boundary. It is a Grade II* listed building along with 50 acres of historic parkland which is within the Pyrton Conservation Area and immediately contiguous with proposed housing allocation site C, PYR1 and PYR2, as outlined in the WNP, where a re-aligned B4009 would pass. The Beechwood Estate is centred around the Grade I listed Shirburn Castle, together with its traditional and historic model estate complex comprising Grade II* and Grade II listed buildings. The Grade II listed Shirburn Castle Registered Park and Garden – at the boundary of the proposed re-aligned route – is set within the curtilage of the Grade 1 listed Castle and is bordered to the east by the B4009 and to the south by Pyrton Lane. Purpose of the representations Our clients have significant concerns regarding the proposals set out within the draft WNP for the safeguarding of land in Watlington for a re-aligned B4009. One of the aims of the WNP is “To safeguard land for a re-aligned B4009 to the north and west of the town in order to reduce congestion in the town centre, to improve air quality and provide a route for some through traffic.” Further to this, WNP Policy P2 (Transport) explains that “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).” This is expanded upon within the Watlington Housing Policies with reference to the three allocated housing sites (Sites A – C), each of which proposes that housing is brought forward alongside a re-aligned route. The decision in the WNP to safeguard land for a re-aligned route recognises proposals within the emerging South Oxfordshire Local Plan (Publication version dated October 2017). Specifically, draft policy TRANS3 (Safeguarding of land for strategic transport schemes) explains that land is safeguarded to support the delivery of a number of identified transport schemes, including a bypass for Watlington. This stems from draft policy STRAT9 (Land at Chalgrove Airfield), which notes that the proposed strategic allocation at the airfield will be expected to deliver, amongst other things: “improvements to highway infrastructure through direct mitigation or significant contributions to new or improved roads, such as a bypass or edge road, including sustainable transport improvements, and where appropriate in association with relevant Neighbourhood Plans and any wider county council highway infrastructure strategy, around, but not limited to Benson, Stadhampton and Watlington, including highway intervention measures to mitigate additional impacts, both transport and environmental, in Cuxham, Chiselhampton, Little Milton, Shirburn and other settlements where justified.” In its November 2017 response to the Publication version of the emerging Local Plan (on behalf of the Residents Against Watlington Ring Road – RAWRR), Entran raised concerns over the soundness of the draft plan (having regard to the tests set out in paragraph 182 of the National Planning Policy Framework – NPPF), as well as its legal compliance, with reference to the proposed safeguarded route. This letter – along with the enclosed representations from Entran, updated in response to the WNP – reiterate and expand upon these concerns, alongside seeking to raise awareness of the potential implications of bypass around Watlington. Basic conditions Neighbourhood Development Plans (NPs) are required to meet a number of basic conditions in order to proceed to referendum. These are the tests that the appointed Examiner will assess a NP against. Of particular relevance is the requirement for a NP to a) have regard to national policies and guidance, and b) ensure that the making of a NP contributes to the achievement of sustainable development. As noted in Entran’s enclosed representations, the bypass proposal does not appear consistent with national policy. It also does not contribute towards the delivery of sustainable development, particularly with regard to sustainable travel and environmental impacts. Of further importance in terms of the basic conditions is the requirement for a NP to be in general conformity with the strategic policies contained in the development plan for that area. In South Oxfordshire, this relates to the policies contained in the Core Strategy (adopted December 2012) and saved policies of the Local Plan 2011 (adopted January 2006). There are no policies in the adopted development plan that supports the delivery of a bypass in this location. The WNP is therefore not in general conformity with the strategic policies in South Oxfordshire. Further to this, the National Planning Practice Guidance (NPPG) explains that “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 (Paragraph: 009 Reference ID: 41- 009-20160211).” The NP Examiner is therefore required to consider whether any reasoning or published evidence have a bearing on whether a NP meets the basic conditions. As explained in Entran’s enclosed letter, there is currently no robust reasoning or evidence at District or Neighbourhood level that suggests that a bypass is necessary or appropriate. It appears that the proposed housing allocations (Watlington Housing Policies: Sites A – C) have been selected ahead of other potential sites, principally because of their ability to contribute land and financing towards a bypass and assist in bringing it forward. This is not a sustainable way of planning for the future of the town. It is acknowledged that NPs are not subject to the same examination process as Local Plans and as covered above, the key test for NPs relates to meeting the basic conditions as opposed to soundness, which applies to Local Plans. While NPs can come forward in advance of an emerging Local Plan, any proposal within an emerging Local Plan will be subject to its own separate examination process. There is therefore no certainty that the proposals in the current (Publication) version of the Local Plan will remain in their current form, or remain at all, by the time it is adopted. In light of this it is considered appropriate that a decision regarding whether the WNP meets the basic conditions awaits the outcome of the Local Plan examination and the adoption of the Local Plan. Notwithstanding the above, should the examination proceed, to assist with this process, a public hearing would be appropriate. This would enable all key and interested parties to have a fair opportunity to express their views on the contents of the WNP. Other considerations Pyrton Parish Council is due to submit the Submission version of its NP for examination. This sets out measures to ensure that the quintessentially rural and tranquil parish is able to conserve what makes this part of South Oxfordshire such a pleasant place to be part of. A key part of the Pyrton NP is the retention of the local gap between Pyrton and Watlington, to prevent their coalescence and to conserve their separate identities and settings. The area of land that provides this gap is identified as PYR2 in the WNP. The safeguarded route passes through this land. Section 6.7 of the WNP explains that the WNP supports Pyrton in protecting this site (along with PYR1) from “inappropriate development that would adversely affect both the Chilterns AONB and the Shirburn Castle Historic Park.” It also identifies that “The WNDP concurs that these two sites are located in a very sensitive landscape area. In particular, PYR 2 provides clear visual separation between the two communities of Pyrton and Watlington. However, the location of these two sites is key to safeguarding the route of the proposed re-aligned B4009.” The above text is contradictory. It acknowledges the value of PYR1 and PYR2 and seeks to protect them from “inappropriate development”, yet the WNP continues to support the delivery of a bypass through these sites. It appears that the intention is that these two sites would contribute towards the funding of the bypass, along with the proposed WNP housing allocations. There also exists no engineering study or traffic research that evidences how the safeguarded route could be engineered to safely cross Pyrton Lane as it emerges from WAT9 and enters into PYR2. Moreover, such a crossing may need to enter into and take up part of the playing fields of Icknield Community College. A bypass around Watlington has the potential to have a number of other significant impacts on the local and surrounding area. This includes the following: • Permanent adverse impact on the local environment, detracting from both Watlington and Pyrton, inducing traffic and not dealing with the air quality problem in Watlington, exposing new and existing residents to poor air quality. The bypass would simply move the problem from one part of the town to a different part of the town, which is not a solution.