Adrian Duffield Head of Planning South Oxfordshire District Council 135 Eastern Avenue Milton Park Milton Oxfordshire OX14 4SB 15 September 2016 Our Reference: 248401 Dear Mr Duffield, Outline application for the erection of up to 100 residential dwellings including vehicular access, public open space, car parking, landscaping and drainage (ref. P16/S2576/O) Land off Pyrton Lane Watlington I am submitting this consultation response on behalf of Pyrton Parish Council. This representation is being submitted in line with the statutory consultation period, which expires on 30th September 2016, as outlined on South Oxfordshire District Council’s (SODC’s) website. Pyrton Parish Council wish to strongly object to this proposed development on the following grounds:

1) Development rationale 2) Soundness of evidence 3) Sustainability

In respect of each of these points, I provide below reasoned justification as to why the proposed development should not be granted planning permission. The South Oxfordshire Local Plan is currently subject to review, with the new Local Plan 2032 scheduled for adoption in 2018. While the Local Plan is not fully up to date, and cannot be relied upon, the new Local Plan is emerging and increasing weight can be attached to it as it nears adoption. It is acknowledged that SODC cannot demonstrate a five-year housing land supply at the present time. However, a number of sites are being considered through the proper process of the Local Plan review and will emerge as allocations in the adopted Local Plan. Paragraph 49 of the National Planning Policy Framework (NPPF) makes clear that relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of

deliverable housing sites. In such instances, the presumption in favour of sustainable development as set out within the National Planning Policy Framework (NPPF) is further enhanced and each site should be considered on its own merit. In the light of this policy context, it is, however, clear from the submitted documentation that the outline planning application does not meet the requirements of paragraph 14. This states that where the policies are out of date, planning permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits. As discussed throughout this representation, the scheme is unsustainable and would result in adverse and irreversible impacts to the character of the area, which are not outweighed by benefits.

1) Development rationale Justification provided by the application for the development of the site is based on three proposed benefits: the provision of a relief road; the provision of a permanent park area; and the assertion that the site will help toward meeting housing needs. Relief road / alternative route The outline planning application proposes a new primary route for traffic. This would run east-west through the centre of the application site, connecting Shirburn Road and Pyrton Lane. The applicant asserts that the provision of a relief road would resolve current traffic issues within Watlington, helping reduce congestion and improve safety and air quality. The road would also provide vehicular access to new residential development. Whilst it is agreed that traffic issues within Watlington need resolving, there is limited consideration within the outline planning application of alternative methods for reducing traffic flow and improving air quality. It is our view that a bypass is not the only option and that it would be possible to address current issues through the introduction of less intrusive and less costly traffic control measures. Further, the site falls within Pyrton Civil Parish, a fact ignored by the applicant, which comprises a far smaller population than Watlington (227 compared with 2,727 (Census, 2011)). The proposed relief road would greatly increase local traffic through Pyrton, particularly along Pyrton Lane, creating a hazardous environment for local residents and road users. Moreover, the proposed road will increase the number of heavy goods vehicles (HGVs) travelling along Pyrton Lane, impacting on safety, air quality, and amenity. Promoting the development of the site on the grounds that it will assist in delivering a ‘relief road’ to Watlington suggests a lack of confidence that the site is sustainable on its own merit, and that some ‘planning gain’ has to be offered to make it acceptable. Furthermore, as set out within the outline planning application, the development would only provide a section of the proposed alternative road, with the remaining sections of the road reliant upon other SHLAA sites coming forward (see

appended plan). This further questions the validity of the proposed scheme and leaves doubts as to the realisation of the proposed road. There is no certainty at the present time that other sites will come forward and other contributions may well not come forward. As a result, the proposed development does not deliver any benefit in terms of resolving traffic issues in Watlington town centre, but rather would result in increased traffic along Pyrton Lane, which is currently a quiet road, to the detriment of local residents and the surrounding environment. In addition, footnote 11 of paragraph 47 of the NPPF states that: “To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable.” Given the reliance of the proposed road on other sites coming forward it is clear that WAT8 is not suitable for development now. Furthermore, as noted within the applicant’s supporting report “The Case for the Alternative Traffic Route”, the alternative route will be delivered and funded by the development of each housing site along the route. The scale of the scheme at 100 dwellings, 40% of which will be affordable, pulls into question funding for the construction of the road and thus the viability of the scheme. Paragraph 32 of the NPPF highlights the need for development generating significant traffic movements to be accompanied by either a Transport Statement or Transport Assessment. The same paragraph states that, in terms of impacts associated with transport movements, decisions should take account of whether:

• “The opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure; and

• Safe and suitable access to the site can be achieved for all people.” The submitted Transport Statement is very limited in its scope and does not provide anywhere near enough detail in relation to the above points. Alternatives to the proposed new road should also have been considered in the Transport Statement. Green infrastructure A ‘green edge’ is proposed as another benefit of the development, providing a permanent green buffer between the development and Pyrton. It is proposed that this would be offered to third parties for long-term management. The details of how this land will be laid out, relevant works financed and managed and maintained for future generations are sadly lacking.

Housing need The development of WAT8 is considered by the applicant as necessary to meet housing needs in Watlington. The applicant suggests a housing need for Watlington of 250-300 homes. Whilst there is a recognised housing need in Watlington, the applicant fails to acknowledge that the site in fact falls within the much smaller civil parish of Pyrton, where there is a much more limited housing requirement. Research undertaken in relation to the preparation of the Pyrton Neighbourhood Plan indicates a potential need for around 20 homes in the parish over the plan period – substantially less than the 100 new homes proposed on the WAT8 site. The lack of acknowledgement of the site’s location within Pyrton Civil Parish suggests either confusion or ignorance of Pyrton’s position within the settlement strategy. Moreover, it is our view that there are sufficient alternative suitable sites within Watlington to meet their housing need. Watlington is identified within the South Oxfordshire Core Strategy as a ‘larger village’ within their settlement hierarchy; Pyrton is classified as an ‘other village’. As set out in policy CSR1, housing in ‘other villages’ is restricted to infill development only on sites of up to 0.1 ha. Development is required to protect local character and distinctiveness and meet the requirements of relevant development plan policies. The proposed development is clearly contrary to policy CSR1, proposing a scheme that is in disaccord with the requirements for ‘other villages’.

2) Soundness of evidence The application fails to answer a number of important questions regarding the impact development of the site would have on the surrounding area and amenity of neighbouring residents. In particular, we draw attention to the following omissions:

• The application is not supported by a noise assessment.

• No contamination assessment has been submitted with the application.

• The Heritage Statement fails to consider the impact of the road or the historic relationship between the site and Pyrton Manor (Grade II*).

• The supporting Phase 1 Habitats Survey refers to a separate Great Crested Newts Report, which has not been submitted in support of the application.

• The application does not refer sufficiently to utilities provision – is there capacity in local services for development of this site in this location?

• The Flood Risk Assessment (FRA) fails to explain how surface water will be dealt with and fails to refer to the springs that have in the past resulted in disruptive flooding within the local area. The development of WAT8 would inevitably result in an increase in the risk of flooding to Pyrton and the listed buildings that fall within the parish. Moreover, the FRA lacks in supporting data and fails to acknowledge the lack of existing infrastructure in the local area.

• There is no indication within the supporting documentation as to how pedestrian and cycle traffic will be able to safely traverse Pyrton Lane. Pyrton Lane is currently a very quiet country lane, with very limited traffic, even during peak hours. Proposals for it to become part of the new bypass would dramatically alter its character.

• Failure to consider the impact of the urbanisation of the site on the present open landscape character between the two settlements of Pyrton and Watlington and the visual prominence of the scheme in a countryside setting which will be exacerbated by the proposed new road which will need to be lit at night.

• No EIA screening request issued. Given the scale of development and the sensitivity of the surrounding area it would be considered good practice to do so.

• The planning argument represents the bare minimum required; the Planning and Sustainability Statement is thin and raises a number of questions as to the lack of policy compliance.

• The Design and Access Statement provides an overview of the density and character of Watlington but not Pyrton.

• The block plan / illustrative layout does not indicate the page size / scale.

• Regarding the Statement of Community Involvement (SCI), there is a clear lack of consideration of a number of concerns raised by the local community. Moreover, limited consultation with residents of Pyrton has resulted in a misleading and inaccurate representation of the local community. For example, as noted earlier and as ignored by the applicant, the site falls within Pyrton Civil Parish, as opposed to Watlington. The applicant has focused their attention on Watlington residents, disregarding the site’s location within Pyrton Parish and the views of the community that will be directly affected by the development,

Purpose of the site It is clear the applicant has ignored the current purpose of the site, which is to avoid coalescence between the settlements of Watlington and Pyrton. The development of this local green gap between the two settlements would weaken its role as a buffer and erode the open nature of the gap. Pyrton Neighbourhood Plan As noted above, the site falls within the Civil Parish of Pyrton and not within Watlington. The applicant fails to acknowledge this fact. Moreover, the site is included within the Pyrton Neighbourhood Plan Area, designated in July 2015. In research used to inform the emerging Pyrton Neighbourhood Plan, the site was identified as providing an important buffer between Pyrton and Watlington. As such, through the neighbourhood plan, Pyrton are looking to retain the site as an agricultural field and green buffer zone. A significant amount of consultation

has been undertaken regarding the emerging Pyrton Neighbourhood Plan to understand local preferences for future development, however this has not been recognised within the outline planning application. The submission also fails to consider the cumulative impact of the scheme. It is clear that a development of this scale within Pyrton – a sensitive and rural area – would result in significant cumulative impact of detriment to the local community, the character of the village and the surrounding countryside environment. The lack of consideration of the Neighbourhood Plan context alongside the lack of consultation with Pyrton parishioners, particularly given the site’s location within Pyrton Civil Parish, is in our view a major omission of the applicant and clearly undermines the Neighbourhood Plan-making process.

3) Sustainability As set out in paragraph 6 of the NPPF, there are three dimensions to sustainable development: economic, social and environmental. The sustainability argument set out within the supporting Planning and Sustainability Statement offers the bare minimum with regard to explaining how the proposals would result in a sustainable development. Economic The NPPF states that significant weight should be placed on the need to support economic growth through the planning system (para. 19). With regards to economic sustainability, the outline planning application states that the scheme will bring significant benefits, first during construction and then providing support for local services. There is, however, no mention of the number of jobs expected and their temporary nature during construction, and little in the way of mention as to how the scheme will provide permanent jobs and support local services. It is a further stated that the provision of the section of road is a further economic advantage of the development. We fail to see how this can be relied upon as an economic benefit considering the reliance upon other sites coming forward for the road to be effective. It is therefore clear that the scheme offers minimal economic sustainability benefits as required by the NPPF. Furthermore, it is our view that viability of the site will impact the deliverability of the scheme and any associated affordable housing provision. The proposed new road connection and other works associated with the delivery of the scheme would be very costly – it is not clear if the applicant has secured sufficient funding to cover all costs. Furthermore, given the extent of the works, there could potentially be issues regarding land ownership that could impact on the deliverability of the scheme. The proposed benefits of the scheme, which in themselves are minimal and certainly do not outweigh the dis-benefits, may fail to be realised should planning consent be granted.

Social Development of the site is considered by the applicant as important in meeting Watlington’s housing needs. The supporting Planning and Sustainability Statement highlights a significant need for both market and affordable housing in this district, noting that the Stadhampton appeal case indicates such gains as weighing heavily in favour of such proposals. As noted above, the site does in fact fall within the parish of Pyrton, not Watlington, where there is a much more limited housing requirement. Furthermore, there are a number of alternative sites within Watlington, more suited to absorbing local housing need and more sustainable. The site currently acts as a buffer between the villages of Pyrton and Watlington, demarcating the two settlements, avoiding coalescence and significantly contributing to the open character of the countryside. By developing the site, even taking into account the proposed park area, this purpose is eroded. In addition, the urbanisation effect on the landscape character is harmful to the setting of the adjoining AONB. Pyrton Civil Parish comprises 78 dwellings, approximately 40 of which are within the village itself. By developing the WAT8 site at a scale of 100 dwellings, the parish would effectively double, adversely impacting the identity and character of village, as well as placing pressure on existing services and facilities. The NPPF states in paragraph 123 that planning decisions should aim to identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. Development of the site would alter the tranquil character of this area creating an urban character in an otherwise open area of countryside. The proposed relief road cuts through the centre of the site, separating the majority of the housing from the parkland. The desirability of the site for future occupiers is questionable – will people want to buy a house within such close proximity of a primary traffic route, designed in accordance with Oxfordshire County Council’s guidance for Major Access Roads. The development would result in a loss of open views currently enjoyed from the public footpath that runs alongside the hedge to the rear of Icknield Community College. Environmental The outline planning application states that the development would result in the following environmental benefits: improving air quality; less risk of damage to buildings in the Watlington Conservation Area; and, improvement to the civic realm in the town centre. Potential improvements in the open land on the site with increased biodiversity and ecological interest are further sited as an environmental benefit.

Air quality It can be put forth that development of the alternative route would merely divert, rather than reduce traffic in the area. Diverting traffic from the town centre would quite likely reduce air quality in this area, adversely impacting biodiversity. In addition there would be a net increase in traffic arising from the development that would increase air pollution. Heritage Pyrton is an attractive village with a number of listed buildings including the grade II* listed Pyrton Manor, grade II* listed Church of St Leonards and a number of other grade II listed buildings. As stated within the NPPF, in determining planning applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected. The level of detail should be proportionate to the assets’ importance (para. 128). Furthermore, paragraph 132 notes that the more important the asset, the greater the weight should be…substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered park and gardens, and World heritage Sites, should be wholly exceptional. Both Pyrton and Shirburn Conservation Areas are defined by their special architectural / historic interest and as such the character and appearance of these area should be preserved and enhanced. The outline planning application fails to provide sufficient explanation of how the development of the site would impact the conservation areas and their settings and how such impacts would be mitigated. The provision of a new road increasing traffic along the edge of the conservation area and the registered Shirburn Castle Gardens would inevitably result in significant adverse impacts to the character of this area. Improvements to the town centre The claim that the new road will result in improvements to the town centre is not substantiated. It is questionable whether the new route will be more attractive to through traffic without the implementation of a range of traffic management measures to slow traffic down through Watlington. Drivers will use the fastest route still unless further traffic control measures are put in place. Details of traffic management measures, their funding and associated impacts on the town centre have not been provided. In addition, the new housing development will in itself generate new car trips into the town centre. Landscape

When considering the application, due consideration should be given to the South Oxfordshire Landscape Character Assessment (1998). Despite the age of the document, a detailed landscape appraisal and development capacity

assessment carried out by Terence O’Rourke have concluded that the council’s assessment remains wholly accurate and relevant in both policy terms and in its description of the Eastern Vale Fringes, in which the site is located. The site is distinctly rural and currently contains few detracting features. Traffic on the B4009, Shirburn Road, is audible but not intrusive and so broadly the landscape resources of the site are consistent with the more positive elements identified for the Eastern Vale Fringes and in particular the Semi-enclosed rolling downs landscape type. In particular, its ‘rural character with few detracting influences and its ‘semi enclosure’ contained by ‘intact structure of hedges, with hedgerow trees and frequent linear belts or stands of planted woodland’ that give rise to ‘moderate intervisibility.’ The South Oxfordshire Landscape Character Assessment states that the ‘semi-enclosed rolling downs landscapes benefit from a more intact landscape structure and strong backdrop of the Chilterns escarpment, but their scenic quality (part AONB) and visual prominence makes them sensitive to development.’ Indeed, this statement is particularly relevant to the site at WAT8, considering the quality and condition of its landscape resources. The development proposals for WAT8 will, then, have a significant effect on both the landscape character of the site and the wider Eastern Vale Fringes, contrary to the management strategies outlined in the councils Landscape Character Assessment. The site was also considered by SODC as part of the call for sites for the new Local Plan. Importantly, the council in their Landscape Capacity Assessment (Aug, 2015) considered that whilst the site would not be visually prominent from within the settlement, it would result in probable views from the Chilterns Area of Outstanding Natural Beauty. The site was, as such, considered to be unsuitable for housing as it would result in “potential harm the setting of Watlington and the AONB”.

While the site is not within the Chilterns AONB, it is within close proximity and as such the impact of its development should be considered sensitively with regards to views and enjoyment of this important landscape. As stated in paragraph 109 of the NPPF, the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes. Full account should therefore be taken of the likely impacts of developments on the setting of the AONB. The site is located within an area of rural land that shares inter-visibility with the Chilterns escarpment and so contributes directly to its setting. The Chilterns AONB Management Plan should therefore be a material consideration in determining the application. The plan places considerable emphasis on the need to value the setting of the AONB as ‘an integral part of the efforts to conserve the landscape of the AONB itself.’ The development proposals will result in harm to the Chilterns AONB as a result of settlement expansion in a prominent location that shares inter-visibility with a valued landscape. The site also functions as an open gap between Watlington and Pyrton Manor grounds (located within the Parkland and Estate landscape type), maintaining the

latters rural and isolated setting. The development proposals will have a negative impact on the adjacent landscape type due to its existing unspoilt character and the urbanising effect of the development proposals, again contrary to the management proposals for the landscape set out in the councils Landscape Character Assessment. It is concluded, then, that the development proposals will result in a significant perception of sprawl, extending beyond the soft settlement boundary and offers limited opportunity to create an improved gateway due to the location of agricultural buildings and recreation ground between the site and the B4009, Shirburn Road. Further effects of the development proposals on the setting of the Chilterns AONB and indeed the containing landscape are considered significant and should be given appropriate weight when determining the application. Conclusion It is clear that the claimed sustainability of the proposed development is highly questionable. The information set out in the application is weak, failing to fully explain how the site will benefit the local area and not result in adverse impacts to the character of the area and an irreversible loss of an open greenfield site. The outline planning application fails to meet the requirements of the NPPF and fails to address the impacts the development will have on a number of important material considerations. It is strongly felt that the scheme represents an inappropriate form of development within a highly sensitive rural area. Development of the site would fundamentally alter the character of the area, introducing an urban feel to an otherwise tranquil area of open countryside. The outline application is weak in demonstrating how the proposal would sustain the town of Watlington and fails to consider fully the adverse impacts on the village of Pyrton. It is our view that it is of the utmost importance to retain the site as a buffer between the settlements of Pyrton and Watlington and important setting to the adjoining AONB. The assertion that the development of the site is required to meet housing needs is flawed; housing needs for Watlington can be met through the development of alternative sites that fall within the parish of Watlington and not Pyrton. Moreover, the proposal is in disaccord with policy CSR1 and the settlement hierarchy set out within the adopted Core Strategy. The proposal does not deliver any benefit with regard to resolving current traffic issues within Watlington town centre. The proposed relief road is reliant on other sites coming forward in order to be effective. Moreover, the proposed road would increase traffic along Pyrton Lane. The lack of consideration of the emerging Pyrton Neighbourhood Plan represents unsound planning and fails to address the real concerns and desires of the local community. The proposal is submitted ahead of decisions relating to the scale and location of development in the Pyrton Neighbourhood Plan Area, undermining the Neighbourhood plan-making process as set out in the government’s National Planning Practice Guidance.

The current proposals do not represent a sound approach to planning, nor do they represent a sustainable form of development as defined within the NPPF. It is our view that the application has not made a case to support the claim that it represents sustainable development and it should be refused. I trust that the content of this letter is clear and will be duly noted, but please do not hesitate to contact me if you require any further clarification. We would consider that it would be helpful to meet with yourself as soon as possible to discuss the application further. In addition, please note that we are currently in the process of preparing further information in response to the application to substantiate the views expressed within this letter. This will be submitted in due course, in advance of the conclusion of the statutory consultation period, which expires on 30th September 2016. Yours sincerely,

Tim Hancock Managing Director cc Pyrton Parish Council Enc.