SECOND PREFERRED OPTIONS
COMMENTS BY SOUTH OXFORDSHIRE SUSTAINABILITY (SOS)
SOS is a coalition of South Oxfordshire Community Action Groups dedicated to promoting genuinely sustainable development, comprising:
Sustainable Wallingford and Cholsey
Henley in Transition
Sustainable Didcot
Green Living Plan for Thame
Goring and Streatley Sustainability Group
Pangbourne and Whitchurch Sustainability Group
Greening Chinnor
Living Lightly in Dorchester
Oxfordshire Chilterns Community (OCCA)
Chalgrove Environmnental Network
Submitted by John Gordon, SOS Chair.
INTRODUCTION AND DOCUMENT.
Despite the fine wording, the consultation process for this draft Plan is flawed and inadequate. Since the Planning Department refuses to send out printed copies of this 224 page document it is, without begging, borrowing or stealing , impossible to read it other than online –which many people find difficult and off putting. Why not print extra copies to be issued free or at low cost to, at least, community groups concerned with planning issues?
We are disappointed that despite our comments on the need for wider and better funded efforts by councillors and Council to meet with and involve local residents in major planning issues (see SOS response to SODC Consultations on Community Involvement, dated 22 February 2017) there have only been a handful of poorly advertised consultations with rather uninformative visual displays.
The quality of the publication is variable and shows signs of hasty editing. There is much repetition, annoying spelling mistakes, a number of photos which barely relate to the text `and only one map, late in the text. This makes it very hard to envisage the overall cumulative impact of what is proposed.
VISION, OBJECTIVES AND PREFERRED OPTIONS
Much that is desirable. We welcome a much stronger commitment to providing the necessary infrastructure for further development. We would all like South Oxfordshire to “remain a beautiful and prosperous place to live in” and “an attractive place for people to work and spend their leisure time”.
But sadly given SODC’s failure to challenge the SMHA the housing figures which the Council has felt bound to accept, together with related new infrastructure will mean that with almost 23,500 new houses many more people will be crowded into our towns, villages and countryside.
The document ignores the country’s legally binding requirement to reduce its CO2 emissions by 80% by 2050 (against 1995 levels). The 1.5 degree of warming agreed at the 2015 COP adds a further challenge and the potential of achieving this through new and refurbished buildings should be at the heart of any Local Plan.
Whilst carbon emissions from new (and existing) buildings will have to be reduced to zero (or carbon negative) due to the difficulties in achieving substantial reductions in other sectors (industry, power generation, agriculture, the military and transport) the Plan should also support the generation of renewable electricity and encourage the development of local agricultural systems (i.e. residential smallholdings on the edge of settlements). Agriculture is responsible for between 13% and 50% of carbon emissions depending on whether land use change is factored in and there is sufficient policy advice in the NPPF to justify the inclusion of a land use policies to seek to mitigate these impacts.
We note instead that while the importance of climate change is indeed recognised in Objective 8.2 little is proposed to mitigate this in terms of, e.g. environmental and design standards for new developments and of the impact of the large scale growth of car traffic which must inevitably result if the Plan is to be implemented.
The major health implications of increased air pollution are also largely understated -though we welcome the first time commitment to take the cumulative impact of pollution into account when considering planning applications. The Government’s plan to reduce NOx seeks to delegate responsibility (blame?) to local authorities. The Local Plan is an opportunity for the Council to expedite the transition to ULEVs through requiring development to contribute to the purchase of electric vehicles and the provision of charging points.
Nor after evaluation by our hydrological experts do we consider that adequate account has been taken of the uncertainties of whether water provision will be adequate for the increase of population envisaged.
For more detailed comments see sections on SETTLEMENTS, TRAFFIC / HEALTH and WATER below.
There are many, and welcome references to “protecting the countryside”, but none to its economic value as land for producing. Despite a very limited reference at the end of policy STRAT1 this is very largely ignored. There is no chapter covering agriculture, forestry and related employment despite their importance in a still largely rural area. With a rapidly growing world population we are going to find it increasingly difficult to continue to rely heavily on food imports.
IT SEEMS ESSENTIAL THAT A NEW CHAPTER SHOULD BE ADDED TO COVER THIS ASPECT, INCLUDING SETTING OUT POLICES TO ENHANCE LOCAL FOOD PRODUCTION.
SETTLEMENTS
SOS do not consider that they can indicate any view for where major development should take place, given our overall perspective on development in the district.
Specific comments however are
1. that phasing of new housing over the life of the plan is essential to enable communities to absorb the growth and not be overwhelmed by it and
2. that it is not enough to specify the pure number of units – communities need balance in the stock of accommodation to secure their future as vibrant communities rather than dormitory suburbs.
DIDCOT GARDEN TOWN.
This proposal has been comprehensively demolished in a recent study by the SmartGrowthUK expert group which concludes:
Despite the hurricane of green-wash and propaganda from public relations practitioners and even some professionals, it is clear that “garden towns” and “garden villages” are no more than simple car-dependent, low-density, greenfield sprawl – environmentally destructive but highly profitable for their developers.
We need to abandon the concept, stem the whole tide of greenfield development and rethink strategic planning along Smart Growth lines. We recommend the Government, devolved administrations and local authorities withdraw support from garden town and garden village developments.
CHALGROVE
There must be strong concerns about the sustainability of any development placed a long way (more than 4 miles ) from the intended employment area if no well-developed transport infrastructure exists – as at the proposed airfield development at Chalgrove which is intended as overspill housing for Oxford / Vale Science Park. Both these employment areas are further than walking distance and no existing regular public transport system in place. This would result in 90% of the travel to work being done by car with typically only 1 occupant – not sustainable or matching UK requirements to reduce our climate impact.
If such remote sites are chosen for housing developments, the resulting traffic congestion from the extra car journeys will require other road improvements to have to be undertaken within the road network emanating from this new development just to allow movement of people to be done in a reasonable time or otherwise the homes will not be occupied.
CULHAM
Residential development proposal west of the Culham Science Centre:
Whilst it is sensible to build housing next to an existing employment site, major infrastructure changes need to be in place before the houses are built:
• disabled access at Culham Station
• doubling of the railway track between Didcot and Oxford so that additional stopping services can be provided for the new residents
• the "Science Bridge" and road linking the new housing estate to Didcot
• cycle track completion between the new development and Abingdon town centre (the current track ends about 1 km short of Abingdon, leaving cyclists with an unpleasant/dangerous experience on the busy A415).
frequent daytime bus services linking the site to Abingdon, Oxford, Didcot and the Harwell Science Centre
TRAFFIC/ HEALTH
In the absence of a countywide spatial growth strategy which would minimize unsustainable development SODC growth plans are predicated on a major growth in road building.
The draft should give much more attention to the wider implications of increased transport, In terms of noise and air pollution, environmental degradation and the dangers to bio-diversity resulting from fragmentation and loss of connectivity of habitats highlighted as a serious threat in Wild ~Oxfordshire’s recent report State of Nature in Oxfordshire 2017.
We acknowledge that some additional road building and roadimprovements will be inevitable, but these should be complemented by a more than comparable, meaningful commitment to the cycle infrastructure. Communities must be connected by safe cycleways and pedestrian paths. Cycling is the preferred means of transport for many people and can make a significant impact on reducing motorised transport. A radical reappraisal of the importance of cycling is required on the part of the planning authorities."
More specific comments:
- Policy TRANS3 should include provision to safeguard land for a northern bypass for Wallingford. This would reduce pressure on the town centre and help address air pollution in the town.
- Whilst sites are to be safeguarded for road improvements, there needs to be a commitment that new development will not go ahead until the road improvements have been delivered.
The County Council’s LTP4 , one of the supporting documents, reports on evidence of modelling the additional commuter trips anticipated based on SHMA predictions of 100,000 houses needed in Oxfordshire by 2031. The model work highlights that the A34, A40, A338 and A4074 would experience severe delays, and that many junctions would become over capacity. It also highlights significant strain on the A40 and the A4074. There is also heightened pressure on the already busy roads around Didcot, Abingdon and Wallingford.)
-We are pleased that congestion problems on the A4074 and other roads in the Wallingford area have been recognised, but there is no evidence as to how they will be addressed before additional housing is built in the area.
WATER
Recommendations in the draft are based on the JBA Associates Water Cycle Study. This Study reaches a number of conclusions highly pertinent to the “Vision” for the District. In summary they are:
a. Water is available in small areas of the District but there is no additional water available for licensing over the majority of the District
b. Improvements are required at all wastewater treatment works except Goring
c. None of the receiving waters meet Good Ecological Status and except for Goring and Wheatley none of the other treatment works have the technology to meet the requirements.
d. Flood risk should be considered with all developments and development diverted to areas where risk is lowest.
To meet (a) in these limitations Thames Water require new developments to reduce water consumption to 110 litres per head per day from the current 160. But this is unrealistic as new dwellings use water more extravagantly and the coming hotter summers will raise demand. Only by bringing in water from outside the District can the demand be satisfied.
Regarding (b) treatment works need to be improved to treat waste waters more comprehensively and to cope with the increased flow. JBA say nothing about the capacity of the sewers to handle the increased flow of waste water. Who will pay for the carriage and treatment of the waste water through the new sewers and in improved treatment works?
For (c) it is important to public health for the state of the aquatic environment that discharges from water treatment works reach high standards, particularly when there is so much reuse of Thames waters.
For flood risk (d) the JBA study says nothing about climate change and the increased frequency and magnitude of intense falls of rain leading to flooding. The 50- year flood is likely to become the 20- year flood, for example, posing an increased risk to development sites and to existing dwellings in certain areas.
These concerns need to be taken fully into account in the final Plan and may, inter alia, lead to a reduction in the areas suitable for housing.
HOUSING
If the Plan is intended to be consistent with the Government’s hope that self/custom building can rise from about 7% to about 20% of a (larger) total of housebuilding the policies would have to be much more supportive of this sector.
Much more publicity must be given to the self/custom building Registers and the Council must be prepared (through the drafting of appropriate policies) to reserve areas for this form of development on permitted and allocated sites (ie 20% on any site more than 5 dwellings).
The Plan should acknowledge the unsustainable level of under-occupation of the existing housing stock and the severe lack of smaller dwellings (consistent with the average household size of about 2.6 and falling). In fact the need to provide a range of smaller dwellings attractive to older households in itself exceeds the total supply of new housing of all kinds being proposed. The Council should refer to Unlocking England’s Hidden Homes (Intergenerational Foundation 2016) for some ideas how the supply of smaller dwellings and ‘downsizing in place’ could be achieved.
NEIGBOURHOOD PLANS
The Plan seems to be relying very heavily on the emergence of neighbourhood plans within the District. Council should not view NDPs as an opportunity to duck its responsibilities to reduce carbon emissions from buildings and transport and develop local agricultural systems. The Local Plan should provide the strategic policies to enable neighbourhood plans to help achieve these objectives.
On the other hand should an NDP show leadership in any or all of these respects it should receive the support of the District Council and not be required to return to policies which have been proved to be ineffective and lead to unsustainable development.
FINALLY - THE IMPACT OF THE JOINT SPATIAL PLAN
Oxfordshire Councils have agreed to develop a Joint Spatial Plan over the next two years. ~The intention is to provide “a tool for considering the future growth of the county in a more coherent way than is possible through separate Local Plans…”
This has major implications for planning in our district –and must throw into question important elements of what will be incorporated in the final Plan – including possibly the location of a number of major developments.
A number of organisations are coming together to help work on this with the aim of ensuring that this core document for planning the county’s future will have a clear commitment that future developments should have positive impacts on reducing our emissions and delivering on targets in the national carbon budget.
If so we hope and expect that some of the more unwelcome and unsustainable aspects of South Oxfordshire Local Plan 2033 , most unlikely to be modified as a result of the current consultation,, will be dropped.
John Gordon
Chair, SOS
May 2017
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