Draft letter to oppose the local plan

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[Objections to the Local Plan – Click for PDF version]

We the collective members of the Hanwell Fields Development Action Group wish to show our strongest objection to the Local Plan, and the proposed development areas referred as BAN5 (north of Hanwell Fields) and BAN2 (Southam Road).

The following points are made as to why the local plan is considered NOT LEGAL.

The misleading of the public – Not Legal
The term of the plan is not in keeping with the National Planning Policy Framework which states that a 5 year land supply is provided along with a 6-11 and 11-15 year ‘horizon’ supply. CDC are misleading the public by adopting the revoked SE Plan for a greater housing number than is actually required. This has lead to public anger, stress and worry over the proposed areas in the plan. This could be compared to the banks mis-selling of PPI and other such financial products. It is simply dishonest and illegal. The need to add such a number of new areas to the current local plan would not be required.

Recommendations: Rewrite the plan to the match the requirements as per the government guidelines and NPPF.

Public consultation has not complied with the Town and Country Planning Act 2012 or the Localism Act. – Not Legal

Cherwell District Council have a duty to allow local residents and communities to have input in to the ‘LOCAL plan’. This has not happened, only now are we being asked in public consultation what our views are on the plan after it has been drafted by the council, where was our input in to the plan?

“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made”.

 “Instead of local people being told what to do, the Government thinks that local communities should have genuine opportunities to influence the future of the places where they live”.

“Neighbourhood planning will allow communities, both residents, employees and business, to come together through a local parish council or neighbourhood forum and say where they think new houses, businesses and shops should go – and what they should look like”.

The local plan has not complied with this !

Recommendation: Ask the residents of Banbury and Cherwell what they want in their area

Areas designated on the local plan have not been measured or assessed on equal or fair criteria – Not Legal

BAN5 has been added to the plan, yet land West of Warwick road has been removed without a valid reason. Previously both sites were joined and listed as one site. When CDC were asked why land W of W road had been removed, it was claimed that it was previously listed as a reserve site yet so was land north of Hanwell Fields. In which case either put both sites or take both off.

Ban5 site has more negative points than positives according to the sustainability report and when 70% of the respondents to the draft plan said they opposed it, citing 36 reasons why they objected and only 7 positive reasons were listed, yet has still been added.  Why ?

Recommendation: Produce a valid and fair scoring system for all proposed areas to comply with and measure them on the same scale.

The following points emphasize our reasons as to why the local plan should be considered UNSOUND

The misleading of the public – Unsound

Disconnection to previous plans, no continuity in approach to planning, with sites being proposed which have previously been dismissed. Incorrect information to try to justify their choice from CDC.

No Banbury Master Plan, included in the Plan are proposals for Banbury that are detailed and specific, but the underlying Banbury Master Plan has not been consulted with the community, nor issued. The detailed plans for Banbury must be removed from the top level Local Plan.

Quality of documentation, Documentation is poorly written, no document management, and full of long winded “planning Speak”

Incoherent CDC website, documentation is difficult to find, there is no organisation between web pages or cross links.

The Northern Boundary – Unsound

Previous Planning requirements, a significant reason for Hanwell Fields to be approved in the first place was Dukes Meadow Drive link road. it was specified to be a permanent limit to the Northern boundary of Banbury within the Hanwell Fields Design 1997 document and as such with previous attempts to get planning permission, to be turned down by previous planning inspectors. This is a significant reason in itself, this road forms a clear, defensible urban boundary to the north of Banbury. Could such a marker be placed to the south of Banbury?

Potential loss of house values in Hanwell Fields. Occupiers had expected to always have green fields to the north.

The right to open space, the previous plans, Draft Core Strategy 2010, Options for Growth Document 2008 and the Banbury and North Cherwell Site Allocations – Issues and Options 2006 all state that we have a right to open space. The proposed plans will take this away from the residents of Hanwell fields by allowing development on land north of boundary road.

Cherwell District Council Capabilities and Competence – Unsound

Doubling the size of Hanwell Fields – Why ?
We’d like to see evidence on what effect the proposed increase in size will have on Hanwell Fields (+120% increase on current estate). We’d like to know why this side of Banbury is earmarked for such large scale developments and why CDC believe they can maintain such a large scale development, not only at Hanwell Fields but around Banbury. CDC have failed to deliver houses in the past, failed to regenerate the Town Centre, failed to create jobs and opportunities and failed to provide the infrastructure to support the current housing numbers, never mind such a large potential increase. Have the Council the skills and acumen to deal with such a large development, after the complete mess they made of Phase 1 of Hanwell Fields (still not complete after 10 years).

The approved Bankside 1 has been available for 4-5 years, for 1092 houses, but none have been built and the 5 year forecast of CDC is for just 50 houses.

Finance
Finance is the key to delivering a housing Plan, as recognised by the Coalition. Bankside1  is a failure due to no finance for builders or buyers. There is no Plan for use of the many Coalition initiatives for finance to get the housing market moving.

Lack of proposed infrastructure – Unsound

Education
The local plan states for Ban5 that 100 primary school places and 80 secondary school places are required for a build of 400 houses. It has been decided in the plan that these school Children will merge with current schools. Unfortunately CDC have not investigated this properly as they would note that the Hanwell Fields Community Primary School is already full to capacity.

With regard to Ban2, although a school has been listed in the requirements for this area, we believe that most of the site will not be developed (land to the east of Southam Road) leaving the development below the required threshold to build an additional school, putting even greater pressure on the current school. The Hanwell Fields Primary School is now under control of an academy status school and as such it is their decision on pupil numbers not CDC or OCC

Transport
The proposed housing numbers for BAN2 would lead to an increase in traffic and we expect to see an additional 2000 cars on the Southam Road between the new development and Tesco Island. There would also be an additional 900 cars from the BAN5 site. Take in to account that Pro Drive are moving to Noral Way (a few metres south of the planned BAN2 Site) in to a custom built factory we estimate a further 400 cars used by employees and visitors, plus the increase in HGV’s

Employment
Unemployment has increased in Cherwell, particularly in Banbury, the local plan has only ONE planned area for employment use, which is the furthest away and at the direct opposite side of Banbury to BAN5. The largest employers in Banbury are the Horton Hospital (1200) which is due to have services cut, Kraft Foods (800) which has been rumoured to be closing for some time and ultimately will and currently trying to sell off some of their land (which would be ideal for housing) and finally Cherwell District Council (700) regrettably public service jobs will be cut in the foreseeable future. The new proposed M40 site has been identified as potential for warehousing and storage. Although a positive number of employment opportunities will arise the number would be low – approx 500 of which a number would not be local people due to skill shortage in the area. CDC have noted in the plan that the growing population is ageing and the requirement to work longer in life due to pension shortfalls, combined with the new retirement age means the skill gap for warehouse and storage operatives will actually increase. Most 70 year olds will not be able to load/unload lorries or carry heavy weight.

There are no plans which would support the development of hi-tech industry in Banbury. Essential to the future success of the town.

Health
The local plan does not stipulate any answers as to increased healthcare provision.

Water
The local plan states there will be water shortage to such a large number of developments

Crime / Antisocial Behaviour / Policing
No answers in the plan to how these will be tackled, CDC is poor at housing the right people in the right house. Large families are placed in small houses, social interaction and development are failing. Bad tenant placement equals bad neighbourhood. 30% social housing simply means we are encouraging a welfare state to prosper. Hanwell Fields already has high anti-social behaviour incidents, building some many more houses will only increase this number. We all have a right to live in a safe environment

Environmental Factors – Unsound

No wildlife survey has been conducted

Excessive development on Green Belt land
One of CDC’s pledges is to protect the countryside. Nearly all of CDC proposed sites  are planned for green field sites on the fringe of towns within the region

An few extracts from the draft local plan 2012

  • (p23 point A.25 last bullet point)
    “Cherwell households have the lowest access to natural green space across the whole of the south east”
  • (p40 point B.84)
    “Cherwell’s countryside, landscape and green spaces are important natural resources. They form the settings of our towns and villages, contribute to their identity and the well-being of Cherwell’s communities, and provide recreation opportunities. The countryside’s intrinsic character and beauty is important to the quality of life in Cherwell and remains an economically important agricultural resource”.

so exactly how does digging them up and building on them change this?

Brown sites – lower than government targets
CDC are currently utilising 25% of Brown Sites, Govt targets are 40%
Local Plan indicates that most sites are on green fields with the exception of Canalside, for the Banbury Area

Aesthetics / Prominent position
Ban 5 is not considered to present a high visual impact, However it will have detrimental effect on the people of Hanwell Fields.

Extract from the Rejection notice of BAN5 site in 2007
“The appellants have underplayed the impact that the proposed development would have on the landscape. There would be a significant encroachment into open countryside beyond the established built-up area of Banbury. The access roads, 400 dwellings, 2 football pitches and a pavilion would detract from the character and appearance of the rural area.”

“The development would have a materially adverse impact on the landscape when viewed northwards from Hanwell Fields (Photo lb, page 31, Document 1). Roads and houses would be clearly visible. When viewed southwards from Hanwell village, the new houses would protrude above a prominent ridge and skyline, despite the intervening trees. This is shown on a wireframe and topographical mesh overlay agreed by CDC and the appellants

“New houses would also be visible on the skyline from the cemetery, about 2km to the east. The explanatory text for LP policy C7 says that development should not protrude above prominent ridges or skylines (CD12). The proposed development would conflict with this policy. (Sections across the site with the proposed dwellings superimposed can be found on pages 28, 29 and 30 of Document 1.)”

“The character of the 2 public rights of way that cross and adjoin the site would be fundamentally changed. They would become urban footpaths through or adjoining a housing estate and not, as at present, rural routes through fields.”

“When the housing at Hanwell Fields was being planned, careful consideration was given to its northern edge, and how it would look when approaching Banbury along Warwick Road. The Local Plan Inspector considered that the spine road serving Hanwell Fields should form the boundary of the town’s development. He also considered that it would be undesirable to have housing on both sides of the spine road (Paragraph 2.13.23, CD48). Hanwell Fields is now almost finished, and the spine road and its adjacent landscaping provide a high quality and well conceived northern edge to Banbury”

Ban2 presents itself as a potential blot on the landscape. The degradation of the DNA of Banbury. Less countryside, market town and  more urban estate.

Site Specific Conclusions
BAN5

  • Previously rejected by Cherwell Council and the Planning Inspector due to the site being considered UNSUSTAINABLE. This is still the case, Car usage will be high and required to commute to places of work and shopping. Proposed transport plans will not suffice. BAN5 is the least sustainable area in whole plan.
    • No plans for education, primary schools in the area are full to capacity, which will lead to even more car usage.
    • No employment area within easy walking distance.
    • No plans for health care – ageing population requires greater health care needs.
    • 99% of residents of Hanwell Fields use their car to go shopping, work etc. Mothers use the car to take children to school from the top of the estate as it’s considered too far and too insecure to walk toddlers to school.
    • impact of anti-social / policing issues.
  •  Development north of Dukes Meadow Drive which is the northern boundary of Banbury Town.

The Design Brief that Cherwell Council defined in March 1997 (and not by developers) states “P2.  point 1.3.1 Location
The land allocated for development at Hanwell Fields is located on the northern extremity of Banbury and will form the new urban edge to this side of town. The objective is to create an urban form and new urban edge which appears organic in character, relating to land form and local colour and therefore specifically distinctive as Banbury”

“P2. point 1.3.2 Prospect
The topography of the site affords extensive views generally northerly over the Area of High Landscape Value. From the proposed westerly neighbourhood park a 270 degree panorama may be enjoyed. Development should be located so as to enable as many people as possible enjoy these views.”

This could therefore be deemed as a contract by which the Hanwell Fields estate was    allowed to be built and had to be contractually fulfilled by the developers of the estate at    the time of building. Any building past the northern edge could be considered a breach of               contract.

This very reason was used by Cherwell Council in 2007 to block the same development that is being proposed at the same site BAN5.

  • The demise of good agricultural land.
  • The urbanisation of the gateway to Banbury which will have a negative effect on the characteristics of the landscape and a greater visual impact on the outlook from Hanwell Fields and Hanwell Village.
  • Changing of the 2 rights of way footpaths. 

 

BAN2

  • Extremely high visual impact on Banbury, viewable from considerable distances including Hanwell Village, Banbury Town Centre, The M40 Motorway (which would have a negative effect on tourism) and important areas and villages around Banbury.
  • Noise pollution from the Motorway would be considerable.
    • Much of the site would be considered unsustainable and could cause a serious flood risk
    • Development is North of Dukes Meadow Drive which is the northern boundary of Banbury Town (refer to the same point on BAN5).
    • The demise of good agricultural land.
    • The urbanisation of the gateway to Banbury which will have a negative effect on the characteristics of the landscape and a greater visual impact on the outlook from Hanwell Fields and Hanwell Village.
  • Aesthetic and landscape concerns are great as the land rises away from the town to the north, the sweeping vista of this land defines the extents of Banbury, it is essential to the town’s setting.
  • The impact of housing on the West of Southam Road has been greatly misleading in the presentation of Rapleys “consultation”
  • The distance from the town would greatly increase the pollution levels
  • There is very poor transportation and access. This is of major concern as no policy exists to alleviate the congestion along Southam Road and down to the Tesco roundabout. The increase in traffic along Dukes meadow Drive would also be unacceptable.
  • No one believes that the CDC suggestion that people will walk or cycle to town from the Ban2 site.
  • The top of Southam Road West adjoins the cemetery, located in a quiet and respectful green area, this tranquillity would be destroyed by the development.
  • The site is not contiguous to any other residential part of Banbury, it is bounded to the South by employment areas

 

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