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Vale Of White Horse District Council

Local Plan Part 2East Hanney Parish

Council Response to Consultation

May 2017

East Hanney Parish Council

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East Hanney Parish Council Response to Consultation May 2017

Contents

1 Introduction.....................................................................................................................4

2 Summary.........................................................................................................................4

3 Scene setting and context relevant to East Hanney.......................................................6

3.1 East Hanney in context of the local environment..................................................................6

4 Fundamental issues which prohibit development in East Hanney..................................9

4.1 School capacity......................................................................................................................9

4.2 Lack of social facilities..........................................................................................................10

4.3 Historic village with limited footpaths and road capacity....................................................10

4.4 Requirement to protect character.......................................................................................11

5 Flooding........................................................................................................................11

5.1 Ground water flooding........................................................................................................11

5.2 Surface water flooding.........................................................................................................12

5.3 Applicability of SUDS solutions............................................................................................13

5.4 Flooding Images...................................................................................................................14

6 Sewage capacity...........................................................................................................15

7 Site 1 – North of East Hanney – Ashfields Lane...........................................................16

7.1 Community Support.............................................................................................................16

7.2 Frontage onto Ashfields Lane.............................................................................................16

7.3 Noise....................................................................................................................................17

7.4 Flooding and Ditch...............................................................................................................18

7.5 Illustration of impact of constraints required for compliance with policy - excluding flooding...........................................................................................................................................19

7.6 Ecology.................................................................................................................................22

7.7 Urban Extension..................................................................................................................24

7.8 Public transport...................................................................................................................24

7.9 Contribution to village facilities...........................................................................................24

7.10 Primary school capacity.......................................................................................................24

7.11 Summation..........................................................................................................................25

8 Site 2 North East of East Hanney.................................................................................25

8.1 Integration...........................................................................................................................25

8.2 Flooding...............................................................................................................................25

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8.3 Ecology.................................................................................................................................25

8.4 Urban Extension..................................................................................................................26

8.5 Public transport...................................................................................................................26

8.6 Contribution to village facilities...........................................................................................26

8.7 Primary school capacity.......................................................................................................26

9 Vale Policies.................................................................................................................28

10 General comment on the Plan – Template and requirement issues specific to East

Hanney..........................................................................................................................29

10.1 Site 7 HELAA Ref EHAN-C Up to 80 dwellings subject to master planning..........................29

10.2 Site 8 HELAA Ref EHAN-D Up to 50 dwellings subject to master planning..........................31

11 Local Community Housing Needs................................................................................32

12 General comment on the Plan – Number of dwellings.................................................33

13 Requirement for community support – Results of the community survey.....................35

14 Benefits to residents?...................................................................................................36

15 Maintenance of local green spaces..............................................................................37

16 Archaeological issues...................................................................................................37

17 Summary.......................................................................................................................39

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1 Introduction

This is the response of the East Hanney Parish Council to the Local Plan Part 2 consultation.

In order to inform this response feed back has been received from members of the community, and a public meeting has been held.

This response has also been subject to consideration by the full Parish Council and was approved at the Council meeting of Wednesday 3rd May 2017.

Members of the Parish Council have met with representatives of the Vales Planning team as part of the consultation and the concerns of the Council and community advised, this written response reaffirms the issues and concerns raised.

We have reviewed the Plan as proposed and have provided our comments within this document. We have some serious concerns and reservations regarding the specific proposals made in relation to East Hanney.

2 Summary

EHPC has held a public meeting which was attended by Matthew Barber leader of the Vale who presented details of the Plan as issued for consultation. Information regarding community support or objection to each of the 2 sites that has been proposed for East Hanney was sourced both at that meeting and subsequently through community outlets. The detailed findings of which are presented within this response.

East Hanney has already been subject to a mass of applications for development, and a village of only 340 dwellings in 2011 has subsequently had a further 211 approved. This represents a significant increase in village size. It is a level of rapid growth far in excess of most villages of this size within the District. This has resulted in the village and community being subject to mass disturbance, construction activity, traffic, and the loss of many areas of green space and open fields. As a consequence the community has really had enough, and is strongly opposed to any further encroachment on peoples lives, and loss of rural and environmental space.

East Hanney is by far the smallest of the ‘Larger Villages’ and indeed has a result of loss of services has fallen below the points threshold, it should be considered as ‘smaller village’.

The additional 130 houses as proposed within Part 2 for East Hanney would with the approvals already received result in an increase in dwelling numbers in excess of a 100% above the base line numbers since 2011. This would represent over development a matter recognized by the inspector who reviewed the local Plan Part1.

There has been no improvement to the village infrastructure and basic services such as waste water and sewage are not able to cope, and are unlikely to accommodate any further development without significant and costly works. This is evidenced by the statements received from Thames Water and the conditions that are now required by Thames water for any proposed development in the village.

It is understood that the Vale wishes for some small sites to be included in the plan to enable delivery during the next 5 years. It is not clear why the Vale considers that the sites selected for East

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Hanney would be capable of early delivery when there are restrictions on infrastructure relating to waste water and sewage which effectively mean that the timeline anticipated may not be possible.

It should also be remembered that East Hanney is subject to regular and extensive flooding. As a result opportunity for development is highly restricted. The flooding that East Hanney receives is violent and extensive. Further detail is provided in section 5. As a consequence of the extent of flooding and flood risk there is very little land within the village not subject to flood which has not already been developed. The 2 sites proposed as strategic sites are both in areas of flooding and are recorded as such.

We do not believe that the Vale will be able to achieve the number of dwellings that it is seeking to achieve from East Hanney because of physical and planning constraints.

We do not believe that the sites are compliant with basic NPPF and the Vales own planning policies, and consequently consider that this aspect of the Part 2 Plan is unsound.

We question why the Vale would wish to try to progress further development here on relatively small sites which are problematic due to natural, landscape, and policy constraints, when the Plan Part 2 already considerably over provides for the number of housing required within Part 2.

That said if East Hanney is obligated to have further dwellings and the Vale considers that despite the over provision there is a requirement, we would wish to work collaboratively with you to achieve a better position for the village, recognizing that the detail of the current plan as provided is neither acceptable to or supported by the community – or indeed in alignment with the emerging Neighbourhood Plan.

Figure 1

Figure 1 shows the two sites (in yellow) proposed in the Local Plan Part 2. These are for up to 80 dwellings to the north and up to 50 dwellings to the north east.

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3 Scene setting and context relevant to East Hanney

3.1 East Hanney in context of the local environment

To understand the impact of the local plan part 2 on East Hanney, first you need to appreciate the village in the context of the local environment. East Hanney is not a sprawling development built in recent years, it is an ancient and compact settlement constrained by low lying flood plains. It was built on raised land within the marshlands which have more recently been worked to provide mostly viable agricultural land.

This land floods on a regular basis, as do the village roads and some properties. The village is not connected to the Abingdon-on-Thames and Oxford Fringe area as stated in the plan, residents associate themselves with Wantage sub area – school children attending Wantage school, the postal address states Wantage and the roads connect directly with Wantage and surrounding area rather than Abingdon.

In the Forward of the plan part 2 it specifically states that it aims to “protects its historic and rural features”, which the residents of East Hanney agree with – any development should aim to preserve the very essence that makes living in Oxfordshire so valued by those that live here and desired by those who don’t. This special environment can only be lost once.

The village has evidence of settlement in the Bronze Age, connections with Roman settlements, with the Hanney Brooch being found in adjoining fields and historically important houses such as Philberds Manor which was home to Edward III and Richard II. The village has grown organically around the various farms and two mills with narrow single lane roads linking the conservation areas which have preserved the historical character of the village until recent times.

The Executive Summary of the plan states that it aims to “Promote thriving villages and rural communities whilst safeguarding the countryside and village character”. This is at odds with the proposal for East Hanney which has seen modern and disconnected development in recent years, the developments of Saxon Gate and Crown Meadow were poorly conceived and disappointingly approved despite objection that little effort was made to connect the design to the village or the rural setting – having little regard to safeguarding the countryside or village character. It is essential for the preservation of the character of the village that any future development aligns with the historic and rural identity, and is not of an urban nature.

Mistakenly, the plan states that East Hanney is a large village which is not factually correct.

It also similarly states that East Hanney is not constrained by the flood plain, this is categorically wrong, as East Hanney is highly sensitive to flood.

Abingdon-on-Thames and Oxford Fringe sub area states:

“The larger villages of East Hanney and Marcham offer a good range of services and facilities and are relatively unconstrained, as they are not located within the Oxford Green Belt, or areas of floodplain, which are both particularly extensive in this Sub-Area.”

The village is very much constrained by flood plain and views to and from the AONB to the south – which had an influence on the inspector of the plan Part 1. It is a rural and agricultural environment with many farms, surrounded by open farm land with many residents still involved in working the land. This is fact and because a report says otherwise does not make that report correct. The village is constrained by flood plains which cannot be disputed – there is much documented evidence of ancient and recent flooding for this low lying floodplain. There are few services, the current ones are

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at capacity such as the village school and sewer systems. There is no commercial shop such as a Co-op and no local community services such as a medical centre, pharmacy or even a coffee shop. The connections with major areas of employment - Milton Park, Didcot or Witney (East to West) are also very poor, there not even being a bus service. Local employment consists of very little, as a result residents travel to employment in Milton Park, Didcot, Harwell, Wantage, Abingdon and beyond.

3.127 states “The Vale of White Horse District consists of a network of historic market towns and other settlements that are set in a diverse and attractive rural landscape. It is therefore important that new development respects the local character and distinctiveness of these towns and villages in the Vale.” This is at odds with the proposals put forward for a further 2 strategic housing sites in the village which will result in loss of rural landscape and local distinctive ness. The local distinctiveness of East Hanney comprises of a patchwork approach to housing development on small scale of less than ten properties, (in most cases individual properties), each built in different styles and materials reflecting the history of the village– this is not in keeping with recent developments where developers are building standard designs of housing which are applicable to urban developments such as Didcot, Wantage and Grove.

The development of 2 sites which are for 40 plus homes, would be in complete contradiction to the nature, style, and fabric of the existing village.

Residents of Hanney have chosen to live in a rural location and are not yearning convenience of employment or services – this is what towns are for. East Hanney residents are looking for a pleasant and peaceful environment – not a busy urbanised conurbation. These islands of relaxed rural space are vital in maintaining what is so important to the Vale’s plan to provide a place where people want to live and work. This is the character that takes centuries to develop and yet can be destroyed in just a few years.

Indeed, and thankfully, the inspector of the Plan Part 1 recognised this character in East Hanney after visiting and appreciating the village in its environment. This ancient landscape needs to be preserved to give local areas such as Grove some connection back to the rural environment as it sprawls across its open fields. It is too late to save Grove but it is not too late to save East Hanney even though the recent growth has nearly doubled the population.

The plan states “3.211 The conservation of the intrinsic character and beauty of the countryside is a core planning principle of the NPPF.”

Again the plan is at odds with this principle – the word intrinsic meaning belonging naturally. It was a travesty that East Hanney was included in the large village grouping due to a scoring system which calculated the value of a settlement based on points which in East Hanney’s case was incorrect. The village should have scored as a small village and still should today – despite the recent growth in housing. This intrinsic village character and beautiful countryside preserved for generations to come.

Even the most hardened developers have recognised the constraints of building in East Hanney. The Parish Council have on numerous occasions pointed out the financial cost of building on marshland. Neither the Steventon road development nor the Dews Meadow development having been completed since planning was granted. The Steventon road development requiring an application to reduce the number of affordable homes to 10% from 40%, due to the additional cost of providing flood mitigation schemes. East Hanney is a flood plain and not a viable “large” village. It is

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constrained by a narrow chalk stream which bursts its banks and floods the existing village on a regular basis.

The areas that have been subject to approvals are shown in Figure 2 below, these have all been approved since the last census in 2011.

Figure 2

Figure 3 shows the recorded population from previous census’s and the predicted population without any further housing as proposed in the local plan Part2.

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Figure 3

East Hanney despite being a rural village with limited facilities has already been exposed to significant and growth. The shape of the curve highlights the exposure, this represents risk on the community, its character, and the landscape.

In the proposed local Plan Part 1 a site of 200 houses was included for consultation and in addition planning applications were made for two separate sites of 200 dwellings each. These were both rejected by the District Council Planning committee and at appeal by the planning inspector.

The planning inspector examining the local plan Part 1 and the appeal both recognised the detrimental impact of large scale development on the historic character and rural setting of the village.

In terms of context it is clear that East Hanney has already been exposed to considerable development to the point that there is now a near doubling of the village. Residents have been consulted and object to further development.

There are considerable physical constraints, and the areas proposed are problematic.

The Vales own policies are intended to protect the Districts heritage and that includes historic villages like East Hanney. It is unreasonable for the village to be expected to take any more development.

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4 Fundamental issues which prohibit development in East Hanney

4.1 School capacity

St James’s Primary School is a central feature of the community and is very well attended. So much so, that the recent demand for places far exceeded the supply of local children requiring attendance in the village. Oxfordshire County Council (OCC) have recently recognised this need and are building additional classroom accommodation to satisfy the current need. Whilst these plans will extend the school, it will only accommodate the demand resulting from the 200+ dwellings that have already been approved and built in East Hanney. There are no plans for further school extension and space-constraints on available land limit future further expansion on this site. To accommodate further additional population a new school on a different site would be needed to satisfy these needs. This is a fiscal and practical issue. It has been verbally reported to us that OCC would not build an expanded new school on this site and, as any further extension is not feasible, any additional children would need to be transported elsewhere for their education.

The village, therefore, could not accommodate the increased demand for schooling that the proposed strategic sites would bring.

4.2 Lack of social facilities.

Social facilities in East Hanney include a War Memorial Village Hall, Sports Playing Field, Children’s Playground, Tennis Club, British Legion Club, one public house, an Italian restaurant, a Baptist Church and a volunteer-run, small community shop.

The War Memorial Village Hall is well-used and both the large and smaller halls are usually fully-booked throughout the year for regular community activities. It is grossly inadequate for the increasing village population and funding for major extension (or similar additional community facility) will be necessary in the near future, even to cater for current requirements let alone for any future expansion of population.

Support for maintenance of a community shop will be crucial for continuing viability of this important village resource. Funding to kick-start additional areas of social activity will be essential to yield sustainability of the well-being of residents for any conceived planning initiatives that are of any scale, even small developments. This would of necessity include development of green spaces with attendance facilities at locations in East Hanney other than those existing in the central part of the village

4.3 Historic village with limited footpaths and road capacity

All the village resources are some way away from both the proposed sites and pedestrian and vehicular routes from either of these areas are inadequate and, particularly for pedestrians, unsafe.

From the site North of Ashfields Lane there is no direct, safe footpath route to the central facilities around the village hall. Ashfield Lane itself is narrow and completely lacking footpaths. The alternative route would entail connection to the footpath to the South of the busy A338 and is of

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greater distance. Hence for most individuals the use of cars to access the central village for any social activity would ensue and put extra pressure on roads and footpaths around the village. These are narrow and pavements are lacking in certain key areas. It is impossible to improve such danger areas because of constraints on available space.

Similar conditions exist for the proposed site North of the Steventon Road. There is no connectivity at all with the sites that are presently built and being newly constructed adjacent to this site.

This area of East Hanney has been developed piecemeal by creeping substitution of prime agricultural land. No obligatory footpath exists from such developments along the Steventon Road to the Hanney Main Street Cross-roads even now after extensive construction here. Such haphazard development has been allowed, encouraged by the Vale Planning Team to determine the 5-year land supply and has gone a long way to destroying the attractive approach to the Lowland Vale village of East Hanney from the direction of Steventon.

4.4 Requirement to protect character

The urban character of building design should not be allowed to continue by the construction of urban-style housing on any site in East Hanney in the future. Due regard for the historic heritage characteristics of the present village must be maintained to offset the destruction of character shown in various of the accepted planning applications to date. There is no excuse for this past deficiency but, now that an adequate land supply is guaranteed in the Vale, more emphasis and regard for this principle is demanded so that complete change of character is resisted.

Furthermore, the visual aspects from all directions approaching the attractive Lowland Vale Village of East Hanney must be preserved for future generations and for existing inhabitants. Without such assurance the quality of life for all will be diminished in the future. It is the duty of all the Vale Planning Team to ensure that this is paramount in any further planning development considerations in East Hanney.

5 Flooding

East Hanney has been subjected to flooding for many years with the primary school head teacher recording significant flooding as far back as 1869. More recent flooding occurred in July 2007, March 2008 and February 2014.

East Hanney is subject to both Ground water and Surface water flooding.

5.1 Ground water flooding

The EA represents groundwater flood risk with maps of groundwater vulnerability to pollution and flooding. The vulnerability map shows areas of alluvium through the centre of East Hanney as intermediate vulnerability and the gravel areas to the east and west of the alluvium as high vulnerability. Figure 4 shows both proposed sites (GF and J) as sites in areas of high vulnerability.

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Figure 4

Both of the sites are highly vulnerable as evidenced by the Environment Agency.

5.2 Surface water flooding

A way to identify potential surface water flood risk both at a specific site and how water from the site may impact on other areas is through the use of the DTM (Digital Terrain Modelling) to identify flow pathways. Modelling techniques using GIS can delineate the natural path that water would take based on the flow direction from one DTM cell to its neighbours and the accumulation of these DTM cells. Flow pathways for the area around East Hanney have been derived on a 1m resolution DTM. These pathways (Figure 5) show the locations of cells which receive water from a minimum of 5000 contributing cells (an area of at least 0.5 ha). The network of these flow pathways is similar to the surface water flood risk and also the river network. The actual path of the Letcombe Brook for example is almost exactly replicated and other drains and ditches shown by the OS map are reproduced. What is interesting however is that the pathways also follow main of the roads, showing that the roads are at a lower level than the surrounding houses and gardens. Sites GF and J show significant flooding pathways.

Figure 5

The Vale of White Horse District Council commissioned a strategic flood risk assessment in 2013 and the resultant study shows the two sites clearly in flood zone 2.

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The following figure shows the VWHDC Strategic flood risk assessment map. It evidences that both sites are identified as areas of flood.

Figure 6

The EA flood Map available via the Parish Online mapping software also confirms that both sites are in Flood Zone 2. This map also illustrates the extent of flood across each of the sites, the majority area of both of the sites is subject to flood.

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Figure 7

5.3 Applicability of SUDS solutions

There is a general assumption that flooding can be alleviated by using SUDS (Sustainable drainage systems). The parish council have not been convinced that these techniques are applicable. In our experience flood risk assessments have been carried out by general engineering consultants that have a poor understanding of flood risk, the assumptions have not been substantiated by suitable bore hole and permeability tests and in addition builders have not implemented agreed solutions.

The applicability of SUDS solutions cannot be assumed until much more detailed investigations have been conducted. The cost of such investigations and possible solutions may mean that the developers will again request reducing the amount of affordable housing and so negate the principal reasons for development.

5.4 Flooding Images

The following images show flooding of the site north of Ashfields lane, Ashfields lane, Ebbs Lane and the A338. Few images of the fields are available as flooded fields were not seen as unusual or significant.

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Figure 8- View north of Ashfields Lane

Figure 9- Corner of Ashfields Lane and A338

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Figure 10- Ashfields Lane looking East

Figure 11- A338 by Ashfields Lane

6 Sewage capacity

Thames Water have carried out a stage 1 capacity study and stated that the East Hanney foul sewer system has reached its capacity. What is not clear at this stage is what improvements are required to

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cope with the additional houses that have been approved and let alone a further 130 houses. Foul water is pumped to the Wantage Sewage Treatment works via a network of gravity drains, two pumping stations and two rising mains. The upgrade works may require substantial and costly works to the gravity drainage network and both pumping stations. There is no guarantee that this upgrade work can be implemented to ensure timely delivery of housing. Thames Water have stated that they need to performed stage 2 study but a start date has not been confirmed.

Consequently, Conditions required by Thames Water because there is no capacity, mean that it is unlikely that the sites proposed would be deliverable within the time frame that the Vale wishes to achieve from smaller sites, and would be entirely dependent on a major upgrade of the system.

7 Site 1 – North of East Hanney – Ashfields Lane

There are some fundamental issues with this site, for example, the area is subject extensively to flood, and matters such as flooding prevent development. It is stated in the consultation document that up to 80 dwellings are proposed.

The following paragraphs with diagrams highlight the concerns and illustrate the constraints which prevent and restrict development. As a consequence it is not possible to meet development here.

7.1 Community Support

It is a requirement of the Plan Part 2 that any development meets community requirements and involves the Community. This is set out in Chapter 2, page 25. This states that Core Policy 4 requires that development will be supported at the additional site allocations through a master planning process involving the community…………where development meets the requirements set out within the Development Site Templates shown in Appendix A.

Engagement has been undertaken with the community by the Parish Council regarding the proposal for development at this site, there is NO COMMUNITY SUPPORT FOR THIS. There is a very high level of objection at 99%. Please see section 14.

Consideration of the site relative to planning policy and physical constraints also shows that the site is heavily constrained and that development as anticipated within the template is not achievable.

We cannot and do not support this, and the proposal cannot meet the requirements.

7.2 Frontage onto Ashfields Lane.

The template assumes frontage onto Ashfields Lane. This has recently been subject of approval for development of 4 large houses. Consequently only a small ‘gap’ remains. The principle of frontage is not possible.

This area that remains is for the main part subject to flood as the diagrams below illustrate

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The diagram below shows the outline of the proposed strategic site, the area in yellow noted ‘4’ which has already been approved for development.

Figure 122

7.3 Noise.

The template identifies that the site may be adversely affected by road noise, resulting in an impact on any proposed residential development.

As the Parish Council and residents we are acutely aware of the very significant affect of noise and traffic disturbance from the A338 on peoples lives. The A338 is a very busy road with heavy traffic loads. In this part of the village, the A338 is also subject to speeding, this being one of the worst traffic speeding and volume areas recorded through speedwatch as monitored by the policing team and local community, reference NAG2.

Residents in housing that has been built recently as a consequence of speculative development complain of their houses shaking, as well as the ongoing noise. There are major road safety and noise issues.

The Parish Council has as a consequence attempted to work with highways in order to find ways of trying to address this very unhealthy and difficult problem. Noise impact assessments are available and highlight the extent of the problem. The diagram below shows the impact. Much of the site is severely impacted and any development would need to be away from the road.

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Figure 133

There are letters of complaint to County Council Highways and to the District Council from residents.

The issue is not just with noise but also with homes physically shaking as a consequence of the very heavy type of vehicles that use the A338 including at night.

7.4 Flooding and Ditch

The site is subject of extensive flood and in our view not deliverable as a consequence. This is the lowest part of the village and thus has a high flood frequency and levels of flood. The photographs provided illustrate the depth and extent of flood. Flood would impact on both any new homes developed here and the neighbouring existing settlement.

An issue to underline is that East Hanney is subject to both groundwater and fluvial flooding. Tests on other sites show that the ground water level is literally just below the surface, to the extent that it is not possible to undertake appropriate tests, bore holes immediately fill. This means that as described in the section on flooding it is not possible to have a SUD solution, or to have any form of attenuation pond, as these fill with water. This means that water will flood, and additional run off arising from any development here will run off and flood the existing neighbouring settlement. Currently the fields retain water and protect this part of the village. The loss of the field to housing would be a disaster, there is very deep concern about the impact of run off from the development and loss of the field which would result in flooding of homes. The NPPF and the Vales own policies protect against this and consequently development here should be prevented.

The diagram below shows the Vales own flood map over lain on the site. Most of the site is within flood level zone 2.

There is very little flood free area.

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There is also a very major ditch that is vitally important for the flow of water from the village. This needs to be kept clear and must not be encroached on. Access is required to this for maintetance.

Figure 144

Whilst we have not further overlain this with the ground water flood map, as described in section 5, and as illustrated in figure 14, there are flood flows through the middle of this site which when combined with the extent of the flood area means that during flood there is an actual flood flow, and not just standing water.

7.5 Illustration of impact of constraints required for compliance with policy - excluding flooding

The following diagram shows the impact of constraints other than flooding on the site.

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Figure 155

When consideration is given to the effect of the Vales own policy requirements as relevant to this site, it can be seen that even without the impact and restrictions associated with flooding, the site is extremely constrained and the number of dwellings outlined in the template not possible!

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Figure 166

When the flood risk area is also taken into consideration and viewed with the diagrams above, it is evidenced that the proposed area is not deliverable.

In light of the issues attracted to this site, the constraints, the strong objection from the community to any development here, and the need to comply with Vale and planning policies:- which clearly cannot be met at this site, this site should be withdrawn from the Plan.

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Figure 177

We would also refer you to the recent appeal by Lagan Homes for their site close to this area which was for a reduction in the number of affordable homes due to the low lying ground which meant that it was uneconomic to deliver the housing without removal of a proportion of the affordable units. The engineering for the site proving on commencement of development to be more costly than would be expected for a normal site outside of East Hanney without such ground water issues. This recent evidence questions the deliverability of this site.

7.6 Ecology

Reference should be given to VOWH Core Policy 46.

Development likely to result in the loss, deterioration or harm to habitats or species of importance to biodiversity or of importance for geological conservation interests, either directly or indirectly, will not be permitted unless:

i. the need for, and benefits of, the development in the proposed location outweighs the adverse, effect on the relevant biodiversity interest;

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ii. it can be demonstrated that it could not reasonably be located on an alternative site that would result in less or no harm to the biodiversity interests;

The approach to the village from the north on the A338 the views are open countryside.

A mature and thriving hedgerow borders the site to the East.

Figure 18- View from A338

Figure 19- View from Ashfields Lane

The proposed site is currently used for horses and as a result no artificial fertilisers are used.

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Local wildlife observations are as follows:

Barn, Tawny and Little Owls

Pipistrelle and Daubenton bats.

Hare, Fallow and Roe Deer, Hedgehogs, Fox.

Once this is lost it cannot be replaced, consequently there is a demonstrable loss of ecology and biodiversity and therefore contravenes CP 46.

It is also clear from the photographs that this area is an important part of the character and setting of East Hanney. It is from its position also impactful on the intrinsic feel and nature of the village as rural.

Loss of these open green fields to development would have an adverse and serious impact on both ecology, and the character and setting of the village as a whole.

7.7 Urban Extension

The site is proposed to be an “Urban” extension, but as has been stated East Hanney is a rural village and an Urban extension is not appropriate.

7.8 Public transport

There are good bus routes to the centre of Oxford, Abingdon and Wantage but there are no bus routes to the identified centres of employment growth which are Didcot, Milton Park and the Harwell Science and Innovation Campus. This proposed development objective does not indicate that it will contribute to the establishment of new bus routes to centres of employment.

7.9 Contribution to village facilities

The location at an extremity of the Village with poor pedestrian access will not encourage residents to walk to the local facilities. Instead they are required to drive and so this will increase local traffic.

7.10 Primary school capacity

The primary school is a significant distance from the proposed site. If places were available it is likely that children will be taken by car to the school. This is already been identified as a major problem with high volumes of traffic during peak hours past the school where there is no drop off or parking facilities at the school. Indeed due to the current expansion the existing school playground which had some limited staff parking is now occupied by temporary classrooms.

The primary school is on a very small site with no room to expand further. The primary school capacity is being expanded but it is unclear if this planned expansion will provide capacity for the approved housing let alone further expansion.

The price of agricultural land is increasing at an extreme rate and the opportunities of purchasing any adjacent land for school expansion cannot be assumed to be achievable.

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7.11 Summation

As set out above - The public consultation returned a response of 99% against this site being included in Part 2. There is no community support for this.

Residents strongly objected to this site for very good reasons and are very concerned about the impact of flooding on their homes and loss of environment.

There are also other issues and constraints which are highlighted above that impact on its suitability. We request that this site is withdrawn from the Plan.

8 Site 2 North East of East Hanney

The proposed site has a number of issues which have not been addressed.

8.1 Integration

The site is bounded on the West side by existing developments which have not been designed or built to provide any vehicular access, nor cycling or pedestrian routes to the proposed site. In addition the site located immediately to the south has been given planning permission for 40 houses and this is a stand alone site with the planning application showing no connection opportunities to the North.

The proposed site can only be accessed by a narrow corridor of land which accentuates its isolation form its neighbouring developments. The proposed site therefore has no integration with its immediate neighbouring housing.

The site is also on the East side of the A338 with the limited village facilities to the west. The A338 has been shown by many traffic surveys to be not only a busy road but a road subject to high speeding traffic and so crossing is hazardous, especially for young children, parents with pushchairs and older people. It is therefore difficult to claim that the site is integrated with the rest of the village.

8.2 Flooding

The site is within flood Zone 2 and lies on very flat land. There are important ditches within the site which drain neighbouring housing sites. Tests on other sites within East Hanney often show very high water tables and poor permeability and so Sustainable Drainage Systems are not possible. The long history of flooding in East Hanney and the generally poor ground conditions do not make these sites a good choice for housing development.

8.3 Ecology

This site, known locally as “Rosie Bees”, is a nursery where plants that attract bees are being grown, evaluated and sold. As a result it supports a large bee population and along with its open grassland has a very strong ecology and biodiversity. With the loss of the general plant nursery to the south and the proposed loss of this bee specific plant nursery there is a substantial loss of ecologically important land which there is no proposal to replace.

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8.4 Urban Extension

The site is proposed to be an “Urban” extension, but as has been stated East Hanney is a rural village and an Urban extension is not appropriate.

8.5 Public transport

There are good bus routes to the centre of Oxford, Abingdon and Wantage but there are no bus routes to the identified centres of employment growth which are Didcot, Milton Park and the Harwell Science and Innovation Campus. This proposed development objective does not indicate that it will contribute to the establishment of new bus routes to centres of employment.

8.6 Contribution to village facilities

The location on the far side of the Village with poor pedestrian access will not encourage residents to walk to the local facilities. Instead they are required to drive and so this will increase local traffic. In addition the objectives do not provide any provision for improved facilities within the village, so there is no extra play area, no additional club meeting space, no additional sports facilities and no additional green areas.

8.7 Primary school capacity

The primary school is a significant distance from the proposed site. If places were available it is likely that children will be taken by car to the school. This is already been identified as a major problem with high volumes of traffic during peak hours past the school where there is no drop off or parking facilities at the school. Indeed due to the current expansion the existing school playground which had some limited staff parking is now occupied by temporary classrooms.

The primary school is on a very small site with no room to expand further. The primary school capacity is being expanded but it is unclear if this planned expansion will provide capacity for the approved housing let alone further expansion.

The price of agricultural land is increasing at an extreme rate and the opportunities of purchasing any adjacent land for school expansion cannot be assumed to be achievable.

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Figure 20

8.8 Summary

There are issues with development at this site. There is also objection to development here as evidenced by the response to this from the community, with a majority opposed.Additional dwellings as proposed would impact on the villages infrastructure and the level of services at East Hanney which are already poor. Currently, as the diagram above illustrates and as noted above, the proposal does not provide for a sustainable development.

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9 Vale Policies

Figure 21

We as a Parish Council are unclear how the proposed sites meet some of the District Councils core policies.

Core Policy 33: Promoting sustainable transport and accessibility• What new cycle routes are proposed?• How does these developments encourage cycling to employment sites and

educational establishments?• How do these developments encourage walking?

Core Policy 35 : Promoting public transport , cycling and walking• How are the impacts on the strategic and local roads minimised?

Core Policy 37: Design and Local Distinctiveness• How are these developments responding positively to the site and its

surroundings, historic character and reinforces local identity?• How do these developments create a distinctive sense of place?

How are these developments linked to high quality Green infrastructure and landscaping to enhance biodiversity?

Core Policy 42 : Flood Risk

Both of the strategic sites are within an area of flood. For Site 1, Ashfields lane there is also significant risk of increased flood risk to the existing village. This area and the surrounding is the lowest part of the village and exposed to major flood risk. The site is used to pump run off water from the neighbouring built environment, the community in the adjacent Ebbs Lane has bought and

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funded its own pump which is required to keep down the water level. Development at this site will breach planning policy and flood the existing dwellings in the neighbouring area.

This would breach both the Vales own policy and the core principle of the NPPF which prevents development in areas liable to flood, and impact on adjacent areas where existing development may give rise to an increase in flood risk. Here the risk of flooding is recent, proven, regular, and significant.

See section on flooding.

• Vale Policy 26: Accommodating current and future needs of the aging population.

How will this be achieved through these developments?

• Core Policy 45: Green Infrastructure

How is a net gain in Green infrastructure, including biodiversity obtained?

• Vale Policy 46: Conservation and improvement of Biodiversity

How will no net loss in Biodiversity be realised?

10 General comment on the Plan – Template and requirement issues specific to East Hanney

We have the following specific comments regarding the templates for the 2 sites at East Hanney. We understand that these represent the template for development at each site and therefore need to be correct and representative of the issues, principles and requirements of each individual site.

We also understand that at the moment they are only high level and outline, consequently we restrict our comments to the matters currently captured, but would have further comment and a requirement to input in the event that it be decided that either of these sites be included in the Plan, as it is taken forward.

10.1 Site 7 HELAA Ref EHAN-C Up to 80 dwellings subject to master planning.

ASHFIELDS LANE – these remarks are not in support of this development, but to clearly identify where planning policies and this plan differ and therefore where the plan should be amended to correct these difference.

We do not consider that there should be any development at this site and it should be withdrawn from the plan for the reasons stated in this document. Reconsideration of the template would identify that the number of dwellings proposed could not be delivered as a result of the material constraints at this location. Not as a consequence of master planning, but as a result of whether any could actually be achieved, and bearing in mind planning policy requirements.

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Key objectives state: To deliver a high quality and sustainable urban extension! This is fundamentally wrong. East Hanney is a small historic rural village in a rural location. We are not a town. We are not even a properly classified ‘larger village’ as we are below the classification requirement. We are the smallest of the larger villages by far. Work undertaken for Part 1 showed that there are several villages classified as smaller which are larger than East Hanney. We are a rural village with a rural settlement and any extension would need to be of a rural nature in keeping with the setting, character, and aligned to the designs and traditions of the existing village. This needs to be captured in the template. It is not acceptable nor appropriate to promote an urban extension of the village as we are not of an urban nature. Please amend the template to state ‘ extension of a rural village nature ‘.

Key Objective: Should also state after East Hanney Village ‘at this edge of village location’

Key Objective: should reflect that the site is not integrated with the centre of the village so residents are not able to easily access existing facilities.

Urban Design Principles: As above the word urban should be removed, and the Design Principles should be amended to also include and reflect:

Retention of village character.

Retention of verges and green open spaces

Protection of the green and soft edge of the village with lower densities

That East Hanney is a clear skies village with no street lighting.

Urban design principles: Remove the statement that dwellings closest to Ashfields lane should have a frontage onto the Lane.

Access and Highways: Please also consider the lack of East West transport, and include provision for East West services.

Access and Highways. Please make provision to consider the impact of the reservoir as stated in the plan Part 2. It will have material impact on transport, access to other parts of the Vale (especially E/W), and has consequences on community, and on the village which will be less accessible due to the loss of the Steventon road, the planned alternative being a much longer and diversionary route.

Please include provision to take into consideration a requirement to meet Aging population and community needs. This is currently not accommodated within the template. Any development needs to meet the requirements of the local community. The chart below shows the demographics.

Landscape considerations. To ensure that any development is of a rural design and in keeping with this older part of this historic rural village.

Landscape Considerations. Please include provision to ensure that the soft edge of the village is retained, with lower densities, and any densities not exceeding the surrounding and neighbouring properties in the conservation area. The approach to the village to have a soft edge.

Landscape considerations: To retain the character of the village.

Flood Risk and Drainage: To state ‘The site is recognised as being subject to flood, resulting in a site wide impact on any development. To consider further if any development is feasible. Detailed analysis with sensitivities modelled at peak flows and flood conditions to ensure protection from

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flood arising consequentially from development. Tests to be provided to also consider the impact on the surrounding environment and settlement which must not be exposed to additional risk of flood.

10.2 Site 8 HELAA Ref EHAN-D Up to 50 dwellings subject to master planning.

NORTH EAST OF EAST HANNEY again for clarity, these remarks are not in support of this development, but to clearly identify where planning policies and this plan differ and therefore where the plan should be amended to correct these difference.

The number of units should be reduced to a level which reflects the actual number of dwellings which could be delivered as a result of the constraints at this location, and bearing in mind planning policy requirements..

Key objectives state: To deliver a high quality and sustainable urban extension!!!

As above this is fundamentally wrong. East Hanney is a small historic rural village in a rural location. We are not a town. We are not even a properly classified ‘larger village’ as we are below the classification requirement. We are the smallest of the larger villages by far. Work undertaken for Part 1 showed that there are several villages classified as smaller which are larger than East Hanney.

We are a rural village with a rural settlement and any extension needs to be of a rural nature in keeping with the setting, character, and aligned to the designs and traditions of the existing village.

This needs to be captured in the template. We recognise that there has recently been some development neighbouring this site and would want any development to both reflect a rural feel, bring about a sense of community, and fit with the immediate surroundings. The template for this site should reflect this. Please amend the template to state ’extension of a rural village nature .’

Key Objective Should also state after East Hanney Village ‘at this edge of village location’. The site represents the frontage to the village when approaching from Frilford on your left.

Key Objective should reflect that the site is not integrated with the centre of the village so residents are not able to easily access existing facilities.

Key Objectives: There needs to be a requirement to relook at this site and the others already approved in this location to reconsider how they could be reworked to provide a sustainable community and make better use of the land. At the moment it is a series of unrelated plots.

Urban Design Principles: As above the word urban should be removed, and the Design Principles should be amended to also include and reflect:

Retention of village character.

Retention of verges and green open spaces

Protection of the green and soft edge of the village with lower densities

That East Hanney is a clear skies village with no street lighting.

Access and Highways: Please add consider the lack of East West transport, and include provision for East West services.

Access and Highways. Please make provision to consider the impact of the reservoir as stated in the plan Part 2. It will have material impact on transport, access to other parts of the Vale (especially

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E/W), and the consequences on community, which will become less accessable due to the loss of the Steventon road.

Please include provision to take into consideration a requirement to meet Aging population and community needs. This is currently not accommodated within the template. Any development needs to meet the requirements of the local community. The chart below shows the demographics.

Landscape Considerations. To ensure that the soft edge of the village is retained, with lower densities.

Landscape considerations: To retain the character of the village.

Flood Risk and Drainage: To state ‘The site is recognised as being subject to flood, resulting in a significant impact on any development. To consider further the extent of development due to flood constraint. Detailed analysis with sensitivities modelled at peak flows and flood conditions to ensure protection from flood arising consequentially from development. Tests to be provided to also consider the impact on the surrounding environment and settlement which must not be exposed to additional risk of flood.

Figure 22

11 Local Community Housing Needs

Information sourced through the Neighbourhood plan survey identifies that there is only limited demand for housing in East Hanney and that the need is for housing for older people. The Local Plan does not accommodate this and therefore does not meet the requirements of its own policy 26.

The following is an analysis of the outcome of the survey, and also identifies that the number of homes proposed in the LOCAL Plan part 2 are far in excess of requirement, particularly when considering that there are already a further [138] homes already approved and yet to be developed. Jointly the numbers far exceed the allocation arising the need to meet Oxfords unmet needs, and the requirement for homes from the local population.

This evidences that the total number of homes proposed under Part 2 for East Hanney is in excess of need.

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Figure 23

12 General comment on the Plan – Number of dwellings

We appreciate that the Council is seeking to ensure that there is a sufficient housing supply for the period of the Local Plan. However, we do not think it appropriate that the Plan should provide for

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such an excess in numbers over and above that required. It is very concerning that the Vale appear to be overproviding bearing in mind the consequences of so doing.

It was confirmed as part of the Part 1 process that the 5 year housing supply has been met inclusive of the buffer. Indeed it is a public statement that 7 years supply is achieved.

For Part 2 and unlike in Part 1, the Vale would appear to have sought to include within the prospectus provision for considerably more dwellings than is required.

Local Plan Part One required 20,560 homes to be provided for. These are all provided for within Local Plan Part 1.

Local Plan Part 2 is required to provide for a further 2,200 homes.

Part 1 and Part 2 together totalling 22,760 homes. Yet the totals under Part 2 seem to add up to some 24,720.

If we understand this correctly this is a doubling of the actual requirement under Part 2!

We consider it important for the communities that live in the Vale, for the environment, and for the economic well being of the Vale, that there should not be any over provision. The District Council should therefore only propose a maximum of 20,560 and the 2,200 additional dwellings required under Part 2. That is a maximum of 22,760 dwellings.

At 22,760 dwellings the number of homes in the Vale will already have grown at a considerable rate and with the changing and considerably different economic influences that has subsequently come into play since the initiation of this process, 22,760 is now probably excessive. Levels of net migration are already retracting, and it is uncertain what the middle to long term demands will be, for example for the services that science Vale provides, and therefore the numbers of people attracted to this area. Access to the UK is also changing, and it does not seem either economically prudent or sound planning practice to make provision within a plan for numbers in excess of requirement when there is no supporting business case, or material planning grounds to do so.

It is very important for the landscape and villages like East Hanney where an allocation may be made, that the environment is not lost unnecessarily to developers under the guise of the Plan. Developers will unnecessarily pressurise landholders, and take and mothball land holdings. Over provision would result in areas of open landscape, village fringes, or sites within villages becoming subject to changes of use unnecessarily, perhaps from agricultural production, or simply becoming held and neglected. This has serious negative consequences on the landscape, occupations, the local economy, communities, and the environment. We feel it is wrong for areas to be lost, put at risk, or suffer adversely as a consequence, when the requirement is for a materially lower total number.

We at East Hanney who are a small community with comparatively little area, have once again been subject to proposals for strategic sites, with 2 sites proposed. We would appear to be the only village with flooding and delivery issues, in this situation, with 2 small sites, as shown in the diagram below. The sites would also appear to be the smallest in the plan, as illustrated by the number allocations highlighted in the diagram.

There is no reasonable explanation as to why we should be exposed to this additional development, with all the consequential disruption and exposure to the adverse and negative impacts of development, that the inclusion of sites brings. The only reason explained to us for inclusion is the

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need for numbers within the plan. Yet the Plan is significantly over provided by nearly 2000 dwellings!

We also understand from the prospectus that the housing numbers proposed for Dalton Barracks are considered to be significantly under that which the site can accommodate, and as a consequence there is already a potential buffer within the plan through that site.

We are very concerned that the plan has over provided and that sites generally which may include East Hanney are being included in this plan at risk to the communities and the environment in excess of need. It is a serious risk and unsound to overprovide as proposed.

Please reduce the numbers in the Plan to the required level of 22,760.

Please look to remove East Hanney from the Plan as the sites are in excess of requirement for the village, and in light of the complexities and issues which have affect delivery highlighted.

Figure 23 (above) shows the 2 sites at East Hanney proposed in the Local Plan part 2. The areas in yellow are sites and units which have all already been approved during the Part 1 process.

13 Requirement for community support – Results of the community survey

Results

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There is no community support for development of the site outlined at Ashfields lane.

There is significant and majority objection to further development to the East of East Hanney at the site proposed - Site 2 which is known as Rosie Bees.

Recognition of the District Councils need to deliver housing under Part 2 and the need for collaboration. We request that the District Council recognise the physical and planning constraints that affect site 1, and the high level of objection to any development at this site from the community. There is no support for this development and consequently we cannot support its inclusion, and request that the site is removed from the plan.

The very major planning issues that are encountered at this site , the consequential planning issues and breaches of National and local planning policy that would be required together with the high level of community objection give sound and robust reason for the removal of this site from Part 2.

It is recognised that the Vale has a need for development of housing, and as set out above East Hanney has already played its part in delivering proportionally more units than most centres, the level of increase already being in excess of 60% as a consequence of applications approved during the part 1 and part 2 process period. Despite this we would identify the availability of an alternative site in the village known as Davis Yard, which would be more compatible for sustainability and linkage to the existing centre particularly if it could be used to provide housing to meet village needs as identified through the neighbourhood plan, being housing for older people.

We are also conscious of the high proportion of residents who responded in objection to the survey regarding the proposed strategic site at the East of East Hanney. Whilst there was some support for this site, we would wish if you were to consider taking it forward for there to be some significant changes so that any development would bring benefit to the village and community. We would appreciate further discussion regarding this and would want to ensure better use of land, provision of community facilities, and better linkage with the surrounding developments and to the village. The community would also need to benefit by way of a contribution through 106 or CIL to the provision of material community assets. To date East Hanney has not benefited from the proportionally large number of developments to which the community has been exposed.

14 Benefits to residents?

The parish council have been frustrated that there has been very little benefit to the wider community despite all the housing approved so far.

A common feature is what little section 106 money is allocated to the community it is designated for items that we do not want or cannot spend.

As an example it is common to allocate money for rugby when we have no rugby club and no rugby field, money is also allocated to cricket when the cricket club is about to fold not from lack of funds but from lack of players.

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So what if the desired benefits are listed in can be plainly seen that none of these have been funded.

• Traffic calming? NO• Increased green space? NO• Enlarged village hall? NO• More children's play equipment? NO• Enlarged village shop? NO• More sports facilities? NO

As part of the Neighbourhood Plan the East Hanney Parish Council have developed a list of projects that should development be approved then these items should funded. These include

A sports pavilion or expansion to the village hall

Traffic calming measures

Increased green space with additional trees, hedgerow, wild flower meadow and open grassland

Outdoor exercise trail

Multi Use Games Area

15 Maintenance of local green spaces

Recent developments have allocated the maintenance of small green areas to a separate management company. The experience is that the maintenance is generally of a very poor standard leading to frustration by the residents. If development is approved the Parish Council would like take ownership of common areas so that they will maintain the areas and have the ability to install, inspect and maintain children’s play equipment that can serve that local development.

16 Archaeological issues

East Hanney has a rich history with many historical finds being found recently. It is assumed that a desk top survey can establish if there is likely to be any remains of historical interest. However, there has been very important finds in locations where there has been no indication of importance from a desk top study.

The Hanney broach for example. In the past few weeks a roman coin, musket balls and evidence of a civil war encampment have been found in a field in East Hanney by the Hanney History Group using metal detectors.

The proposed sites are close to the village, near the route of an old Roman Road and also close to Roman remains to the East. If development should be granted then Archaeological investigations including Resistivity, Magnetometery, test trenches, field walks and metal detecting surveys must be conducted before any works are carried out.

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Ms A Baynard presented a post on the importance of metal detecting for archaeology at the 2014 Landscape Archology Conference and used East Hanney finds as an example. A map showing finds in areas which were investigated to the south of East Hanney is shown in Figures 24 and 25.

Figure 24

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Figure 25

17 Summary

In summary the East Hanney Parish Council do not support the proposed allocation of two housing sites within the Local Plan Part2.

A public meeting held, together with a residents survey, substantiated very strong objection to both of the strategic sites proposed within the plan Part 2 for East Hanney.

As East Hanney is a small village in a small contained area, any inclusion of these sites would have an adverse and negative impact on the whole village and community. Particularly Ashfields lane (North East) which affects the approach to the village, and therefore the setting and the character of the village as a whole, as well as the conservation area and residents. It is very important to ensure that development is not allowed to happen here at this site, and that is the overwhelming response of the community.

East Hanney has since this process began already been subjected to significant levels of housing development. Accordingly, the community is strongly opposed to any further development through the Plan, which in light of the

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level of housing already approved since 2011 would represent over a doubling of the size of the original village, and considered as over development. These are relatively large sites compared to the size and structure of the village and therefore out of keeping and out of context.

It would be harmful and damaging to the village, its setting, environment and character to include sites in East Hanney for development in part 2.

Further, East Hanney does not have the infrastructure to support any additional development of this scale. It is not a suitable village for further development, the village being of a rural and historic nature within a rural setting. Further, the major natural features of this immediate area, and physical constraints which mean that it is not suitable for development, and any such development may not be deliverable.

We have identified in this paper the constraints on these 2 sites, particularly flooding which severely impacts the village and the sites proposed.

We have also identified that the Vales own policies cannot be complied with and that in addition key requirements of the NPPF are not met.

East Hanney is not appropriate for urban extension, as East Hanney is not urban, it is a rural settlement.

It is important for the district as a whole to protect villages such as East Hanney, its character, and its heritage.

We strongly request that the District Council withdraws the site at Ashfields Lane (East of East Hanney) from the Plan Part 2, as this is neither supported, nor practical considering the complexities of the site, including flood.

We also request that the Vale considers withdrawal of East Hanney as a village from the plan part 2 as a whole; this is in light of our size, the constraints for development, and the negative impact that any further development would have on the village.

If however the District Council decided despite the objections to inclusion, and the issues concerning deliverability, to retain one or both of these sites within the local plan then the Site Objectives should be substantially modified and the Parish Council would wish to work with the District Council in production of this masterplan.

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