November 2021

Foiv’s response to DevComms/OCHL’s first consultation on the Horse Fields

22 October 2021

Dear DevComms and other recipients

OCHL Newsletter and online consultation on SP42 Meadow Lane/Horse Fields and Memorial Field, Iffley. Response from the Friends of Iffley Village (FOIV).

Thank you for the OCHL Newsletter which we understand has been widely distributed to households in the area, and the link to the online questionnaire.

Rachel Falconer, lead on the Horse Fields, has been in correspondence with Helen Horne (28/9-5/10) and again on 7/10, as well as with Susan Brown (11/10), outlining FOIV’s queries and concerns. We look forward to receiving responses to the issues raised.

As you are aware, the stance of the Friends of Iffley Village is that the Meadow Lane fields should remain as green space; most recently publicly stated by then FOIV Chair, Mike Starks, at this year’s AGM: ‘The Friends of Iffley Village (FOIV) argued back in 2018 that both fields [includes Memorial Field] should stay green and that remains our stance…’.

Without prejudice to this position of objecting to proposed development on the Horse Fields/Meadow Lane, we offer the comments below. We have encouraged people to respond individually too.

The recent FOIV survey of its members shows that most of them (78%) are opposed to the proposed development, with 92% concerned about increased traffic. With regard to the OCHL newsletter, many of our members’ wider concerns also come to the fore. You may be aware that over 58,000 people have signed an online petition in support of saving the Horse Fields*.*https://www.change.org/p/oxford-city-council-save-the-fields-in-iffley-village-for-community-and-nature

Please note there are discrepancies between the information provided in the newsletter and what is online. Some of these – such as the reference to ‘the latest emerging masterplan’ (under Landscaping, Ecology and Biodiversity on your portal) will only be seen by those visiting the website. In the brochure, the phrase used is ‘emerging proposals’ which suggests that things are not yet set in stone, ie already decided. The significance of this is seen below, under the section on the portal’s Key Proposals (p 4).

Below please find our specific responses in regard to: A) the OCHL Newsletter, B) the online Questionnaire and C) the online Portal.

A) The newsletter

1) The glossy newsletter appears to be more like a sales brochure than a consultation document. The proposed development is spoken of in glowing terms, with aspirational comments – such as a ‘target’ of Passivhaus standards, rather than factual information – and other marketing ploys such as using stock photos of large communal spaces and playgrounds whereas space is actually very limited on the proposed site. The document seems ill-thought out and quickly assembled.

2) On p 2 it states: ‘Had OCHL not been successful in purchasing the land, it would likely have been acquired by a private developer, with less certainty on the type and quality of home provided’. This suggests that the Planning Department would allow a private developer to get away with lower quality housing. We sincerely hope the Planning Dept applies the same and correct criteria to all developments, not favouring certain individuals or developers. Please confirm.

3) The density of the proposed development is inappropriate to the space and the rural setting. In addition, there are to be 17 parking spaces, deemed ‘an appropriate number’ in the brochure – why not spell it out? Seventeen parking spaces for 31 houses will likely be seen an insufficient – especially by those purchasing the full-market price houses.

4) Overspill parking will affect the already congested Iffley roads, but it will impact especially adversely on the Oxfordshire County Council-designated Quiet Route (OXR18) that runs along

Meadow Lane and Church Way from town through to Littlemore. More parking on Meadow Lane will displace visitors’ and service vehicles, but more significantly also those of the carers who need to park there to attend residents in Lucas and Remy house.

5) This Quiet Route is used by hundreds of vulnerable road users every day, including horse-riders, people pushing buggies, mobility vehicles, joggers, cyclists and pedestrians. The County Council has designated Quiet Routes as part of its Active Travel work. Clogging up a key Quietway like Meadow Lane, both with more parked cars and a busy entrance/exit for 31 new houses just does not make sense. Has OCHL taken this key concern up with Oxfordshire County Council, and if so, what is Oxon CC’s response? Please advise us.

6) The diagrammatic map does not give relevant factual information. For example, it does not make clear what type of houses are proposed where; nor how high they actually will be; nor how many rooms they have. Among the leafy greenness there are significant problems to be addressed. For example the SP42 recommendations criteria state: ‘Development should be relatively low-density and two-storey with front and rear gardens and stone-walled boundaries.’

Some of the proposed dwellings do not have front and rear gardens and it is not obvious how many storeys they will be. What is the answer?

The positioning of the proposed houses fronting Meadow Lane suggests that the ancient hedgerow will be dug out; and the one between the two fields. Is this the case?

7) Oriel Meadow, glibly referred to as ‘linking’ from Memorial Field, is not labelled on the plan map. Currently it only has permissive access for the public. Has OCHL negotiated public access as of right with Oriel? If not, it appears the brochure is disingenuous and we ask that OCHL clearly retract this on its website and in subsequent consultation communications.

8) The SP42 recommendations criteria state that the ‘impact of development on views through the riverside edge landscape of the Cherwell meadows to the west, and views back to Iffley from the west should be considered’. The newsletter/proposals do not suggest that these have been considered. The proposed houses placed at the top of the field near the Church Way entrance will adversely affect the stirring view down the slope of the field and beyond; a view which is a welcome relief for the senses of the many who pause there. Please advise how you have met the requirements of SP42.

9) The wonderful old green hedge bordering Meadow Lane is given little or no mention. It is a haven for plant and wildlife offering sanctuary for birds and other creatures. This is an inherent part of Meadow Lane and a much-loved natural element. It enhances Oxford’s rural aspect and deserves to be considered properly as a natural asset. The same is true of the hedge dividing the two Horse Fields, which also looks as if it is to be removed in the site plan. Please clarify the extent to which you plan to remove these hedgerows.

10) There is little evidence in the newsletter of consideration of the Climate Emergency, despite Oxford City Council having policies to respond to it. The wording in the newsletter seems full of tick-box marketing phrases such as ‘a landscape-led development with potential for a new publicly accessible green corridor through the Memorial Field linking to Oriel Meadow, combined with new landscaped… to promote wildlife’. How will nature corridors along the Thames be maintained?

11) Drain management of waste water and of surface water run-off by the attenuation SuDS, as indicated in the proposal, are likely to be very problematic and the concern is that they will result in increased local flooding and pollution of the river. Should a combined system be installed, the geo-physical nature of the field, local flood risk levels, loss of absorptive capacity and extreme rainfall events of climate change make sewer-storm drain overload and raw sewage discharges into the river likely to increase (1,822 hrs during 2020 in Oxford East). A separate system will increase pressure on the nearby sewage pumping station, given the c.13,000 litres per day domestic waste water production from this proposed development. What steps is OCHL taking to address these issues?

12) Building houses next to the stream at the western boundary is cause for great concern, not only because of the direction of flow on the Horse Fields but because any changes to bank height are likely to affect drainage patterns in both fields, shifting the location of surface-water pooling as well as increasing flood risk and flooding in lower Meadow Lane. What evaluation of the future flood-risk and flooding of Meadow Lane has been done?

13) The Horse Fields/Land at Meadow Lane has a large and active badger sett. What steps are in place to protect this protected species from the contractors in the first instance, and then from the houses and their inhabitants, should the development actually go ahead?

14) The newsletter does not mention the two other developments planned for Iffley Village at Court Place with its increased number of units, or at Iffley Mead just 200 m across Meadow Lane where at least 84 homes are to be built. Together the proposed three developments will hugely impact on Iffley, its nature and greenness, its streets, parking, quiet route, traffic, sewers and services thereby rendering this pleasant rural spot enjoyed by the whole Ward of Rose Hill and Iffley, and beyond, into another urban sprawl. What overall assessment has been done of the combined impact on Iffley?

15) Should developments go ahead, much thought will need to be given to handling the construction phase and traffic implications on this congested village. What are your plans?

In conclusion: the newsletter is misleading and does not address some key points of concern – set out above. How can building on an ancient meadow actually help nature? We feel our objections to this development are reasonable and well-founded.

B) OCHL’s online Portal for Land at Meadow Lane

i) Home page

– ‘High quality affordable homes’ p 1 – is highly misleading on a controversial point. Only 15 will be this, and only 12 of this 15 will be social housing = 3 affordable. And ‘affordable’ means 80% of Oxford market rates which is not affordable to most. The remaining 15 or so houses will be sold at full market price. Can you confirm that you will make this clear in your future literature and consultations – ie the extent to which the Council is seeking to develop a rural Conservation Area with housing to be sold at full price?

ii) Under Background

‘As part of the wider contextual analysis of the site the team have undertaken extensive ecological surveys establishing a number of different species on site’ – please could you make these surveys available to FOIV and the public.

– The comment about ‘no bat activity’ is hard to believe, given local knowledge and first-hand observation, as well as the bat reports recently produced for the OUD development at Court Place Gardens, also in Iffley (these are available upon request to OUD). Please clarify.

– ‘There has been one common lizard found so far. Further visits will be undertaken to ensure no further lizards are found’ – this is a prejudicial statement. Please clarify.

– What habitat and green corridors are being secured for the survival of wildlife, following the loss of habitat and foraging area on the Horse Fields?

– Sustainable drainage – please share the surveys done.

iii) Under Key Proposals

Under A Sensitively Designed Scheme

– This connects with the use of the phrase ‘latest emerging masterplan’ under Landscaping, ecology and biodiversity referred to on p 1. If indeed this ‘masterplan’ is being landscape-led, then landscape concerns need to inform the planning from the outset. This is clearly not the case, since the portal wording then goes on to say that the Landscape and Visual Impact Assessment (LVIA) has not been completed yet: ‘The design of the scheme will also reflect the Landscape and Visual Impact Assessment (LVIA)which is being completed by an independent landscape specialist. This will ensure that all sensitive views from local locations will be checked to ensure that the development does not significantly impact on existing views.’

Clearly, ‘landscape-led’ is not the case, and is highly misleading.

– Also, use of the phrase ‘latest emerging masterplan’ points to the fact that previous versions of the masterplan have been produced. Why have we not been informed of these?

– Misleading phrases such as ‘Scale and design of housing to reflect the surrounding built environment’. What does that actually mean?

– The Local Plan 2036 calls for ‘relatively low density’ and ‘sensitive housing infill’. The Key Proposals sketches show a development that is high-density, with little or no communal green space.

– It is not clear where the different types of housing are situated on the plan. Please specify which houses are for sale at Market Rate, Affordable Housing and Social Housing. Are they all to be houses with two storeys, with ‘front and rear gardens’ and ‘stone-walled boundaries’ as stipulated in LP 2036? The Masterplan suggests that the development will create a two-tier community, with social housing crowded into two blocks facing each other across concrete, and market-priced housing provided with private green space and off-street parking. The twohouses proposednear Church Way underline the social inequality: they share an exclusive private driveway and two parking places apiece, while those in social housing will have none at all. Further, their position at the top of the Horse Fields destroys the pleasant view enjoyed by anyone walking down Tree Lane, or walking along Church Way.

iv) Under Site Masterplan

– Some features appear to be incorrectly labelled, such as the cycle storage (no. 15) which seems to be in someone’s garden, while no. 4 on the other map locates a ‘Species rich wildflower meadow’ in the middle of an access road. Do you mean that this is existing species-rich wildflower meadow that will become an access road? Please explain.

– There is no reference to necessary surveys, for example on biodiversity, groundwater or site-specific flood risk assessment, or potential impact on the SSSI across the river. We cannot comment on your proposals because there is no evidence of their being deliverable within the development plan policy. There is a lack of evidence here to indicate that the Site Masterplan is deliverable.

– The decision to choose Meadow Lane as the main site access has not been adequately justified with reference to highways reports. Indeed with respect to the proposed Site Masterplan and Highways and Access, FOIV has identified problems with parking provision and Highway capacity, which will be fully articulated in due course.

– The supporting text to the policy (para.9.201) says that the views to the riverside edge landscape to the west should be considered. The illustrative layout reveals that, far from that having been taken into consideration, the issue has been ignored: there is a line of buildings blocking views to the river from Meadow Lane, with suburban rear gardens stretching right to the river bank.

v) Under Memorial Field

– referred to as Memorials Field lower down.

– Please ensure that this will not used as the biodiversity net gain required for the developer to fulfil their BNG obligations.

– FOIV and the village need a cast-iron guarantee that the Council/OCHL at a future point – when current councillors may have gone and Oxford’s pressing unmet housing need is still there – that this will not be built upon. What mechanism will the City Council enact to ensure this safeguard in perpetuity?

C) The online survey

a) Feedback on Masterplan

– Most of the questions cannot logically be answered, and the sliding scale does not allow for abstention. Please ensure that future consultations are logical and allow for abstention.

– 450 characters is insufficient for text boxes. Text boxes should invite people to submit further comments on email, with the email address alongside. There is no indication on this layout that longer comments will be accepted via email. Please ensure you include this information in future.

b) Feedback on Memorial Field.

– 450 characters is insufficient. Text boxes should invite people to submit further comments on email, with the email address alongside.

Clearly the future of the Memorial Field will need much further consultation. If the Horse Fields are lost to biodiversity, obviously there can be only limited public access to the Memorial Field. It cannot simultaneously be a public park and a haven for remaining wildlife. Issues such as security; the location of the entrance/exit; the field’s long-term management plan and the proximity to No 66 Church Way’s wooded area all need to be addressed.

We look forward to receiving your detailed response to this letter at your earliest convenience so that we can advise our members.

FOIV Committee

planning@friendsofiffley.org

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