Responding to Horse Fields Planning application

/ Planning Documents
As you know, this application is now live; deadline is 10th February. We have compiled some pointers for those who wish to object to this application in the Iffley Conservation Area. We are well aware that some members do not support this stance, and of course they can make their views known to the planners also.
Horse Fields – as they areand as they may become…
PROPOSED DEVELOPMENT OF THE HORSE FIELDS AND MEMORIAL FIELD, IFFLEY VILLAGE – TIME TO LET THE COUNCIL KNOW HOW YOU FEEL!

The long-anticipated planning application for the Horse Fields development (reference 22/03078/FUL) has been made. For those who want to object to or otherwise comment on this application, the clock is now ticking. The City Council has indicated a deadline for receipt of comments of 10th February.

A step-by-step guide on how to make comments on the application is provided at the end of this note.

ELEVEN KEY ISSUES AND CONCERNS TO RAISE WITH OXFORD CITY COUNCIL

An initial review of the application plans and documents by Friends of Iffley Village (FOIV) committee has identified the following immediate concerns about the application[1]. FOIV committee believes that this review already vindicates concerns that this site has never been suitable for development and consequently that the proposals represent unsustainable development that does not comply with planning policy. They urge members to object and to encourage others to do so, either by filling in the on-line form on the Council’s website (see attached instructions), or by e-mailing their reasons for objection to the case officer Michael Kemp at MKEMP@oxford.gov.uk

1. Harm to the Iffley Conservation Area: This is a greenfield site that makes an essential contribution to the integrity and setting of the designated Iffley Conservation Area and which is critical to the retained rural character of the village. These meadows are as unique as other irreplaceable heritage assets in the city that no one would dream of building on. The developers themselves acknowledge that there will be significant harm to the Conservation Area, and to the local landscape setting. The proposed widening of Meadow Lane will create a suburban access road, thus losing the distinctive ‘rural quality’ of the lane valued in the Conservation Area Appraisal. The addition of pavements, changes to the Church Way gate entrance and the junction of Meadow Lane and Church Way will further suburbanise these lanes, harming the rural character of Iffley.

2. The affordable housing would be better delivered nearby on Iffley Mead: The proposed provision of affordable housing can be met nearby at the Iffley Mead allocated site by increasing the amount of affordable housing built there and reducing the proportion of housing built for profit there. This is a clear, proximal and more sustainably sited alternative for the proposed housing provision, with much lower environmental impact. The question of such alternatives has not even been considered in the application, despite the established policy requirement to avoid environmental harm where possible.

3. Road access, traffic and conflict between vehicles and other users of the Meadow Lane ‘Quiet Route’. Development of the Meadow Lane/Horse Fields site would generate significant traffic and parking problems along Meadow Lane and spilling into surrounding areas, both during construction and after completion. Amongst other things, this will significantly degrade the attractiveness, safety, tranquillity and use of the County Council’s own designated ‘Quiet Route’ (OXR18) along Meadow Lane which is intended to protect this sustainable pedestrian and cycle link between Iffley Village, Rose Hill and Littlemore into the City. The Quiet Route is used by thousands of walkers, joggers, cyclists, horse riders and disabled users as a car-free route into east Oxford or further into town, or as part of the much loved ‘Iffley Loop’ walk. A significant length of this Quiet Route will be urbanised, opened-up to increased volumes of motorised traffic and reconfigured to allow two-way use, destroying its tranquillity, safety and character as noted earlier.

4. Parking and highway safety: The proposed development proposes too few parking spaces for the cars it will generate: less than a 1:1 car parking ratio, with only 17 spaces, unallocated except for 2 houses off Church Way, for 32 homes and an estimated 161 people. Overspill parking along Meadow Lane outside the development will present a hazard for two-way traffic, likely requiring widening, loss of vegetation and highways improvements that will further urbanise the route and harm the conservation area. The junction between Meadow Lane and Church Way is already hazardous and not suitable to take the additional volume of traffic, potentially entailing further urbanising works and signage. A cycle path would decant cyclists through the development onto a busy blind corner on Church Way. The National Planning Policy Framework states that ‘development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.’ This is clearly the case in these proposals.

5. Unsustainable location: The application suggests that it encourages the new occupants to prefer sustainable transport modes, but the development is not in a sustainable location, being further from schools, bus stops and supermarkets than the Council’s own policies recommend. Use of sustainable modes will be further discouraged by the harm to the tranquillity, safety and attractiveness of the Meadow Lane Quiet Route. These factors will simply encourage increased car ownership and use, not reduce it.

6. Loss of wildlife/biodiversity: The applicant acknowledges that there will be significant loss of biodiversity locally due to the development. Its own ecology surveys, and those commissioned by FOIV, show this to be a site with high biodiversity value, consistent with its position at the junction of several wildlife corridors. As well as a resident badger population, including a rare white badger (‘Luna’), the site is acknowledged by the applicant as being of ‘county importance’ for invertebrates and to support other protected species. It is the only known site in the City for no less than 9 species of rare bees, beetles and moths, and many of these are also very rare in Oxfordshire generally, and of high conservation importance nationally. The applicant has failed to recognise that the land comfortably meets the criteria for designation and protection as a City Wildlife Site. In part this is because the applicant’s wildlife surveys are deficient and missed important species, including protected species such as grass snakes and bats. In fact, no bat activity surveys were done at all, and consequently the presence of the rare barbastelle bat was completely missed. We don’t yet know exactly what they propose to do with the badgers as full details have not been provided, but they cannot survive within a development site.

7. Displacement of biodiversity: The applicant admits that the development will cause ‘net loss of biodiversity’ and that this means it fails national policy tests. It proposes to pay sums of public money into a pot for habitat creation to offset this somewhere else in Oxfordshire. No detail is provided about this. ‘Exporting’ biodiversity outside the City to make room for development degrades the City environment, is poor and irresponsible practice and does not comply with relevant guidance and policy.

8. Ecosystem services: The Council has undertaken no assessment of the ecosystem services the site provides in its present state. As public land, local people think it should be made available for use for education and appreciation of its wildlife value. Local people have created an alternative vision of a Meadow School which local schools say would meet a defined need and which is much more in keeping with the Council’s own policies for access to and contact with nature and the wellbeing and societal benefits that this generates, as well as protecting carbon stored in soils and trees and helping to prevent flooding.

9. Drainage, flooding and sewage: The surface water drainage design proposed for the development is straight out of the 1970s with almost everything piped and stored underground. This is no longer an acceptable approach to sustainable management of surface water and increases the risk of flood risk and pollution due to system failure. Oxford Sewage Treatment Works is already c.39% under-capacity and OxPlace has failed to secure commitments that it can safely process additional waste water from161 residents. This puts further pressure on Oxford Sewage Treatment Works, adding to system overload and more raw sewage releases into the river. Please object to this archaic and non-sustainable approach. We hope and expect the Environment Agency will object to this archaic and non-sustainable approach.

10. Broken promises on Memorial Field: The Council’s proposals for Memorial Field are unclear. The Council has long promised that Memorial Field will remain undeveloped and preserved, but there are various references to proposals for landscaping and amenity use, and use as open space. Using Memorial Field to deliver landscaping and amenity space means that it is being treated as part of the development site, breaking the Council’s promise. These uses are contradictory and generate practical challenges that have not been considered at all.

11. Poor design standards and error-strewn documents and plans: Overall, the application is poorly put together and contradictory in many respects. It refers to the location as ‘Iffley ward’ which does not exist. Some reports use out of date plans, and other reports are missing. Photos are incorrectly labelled. It seems rushed and disjointed. The architectural design is a departure from what was previously proposed and uses incongruous materials, increased density of housing and reduced provision of green space, increasing the harm to the conservation area.If you agree with FOIV committee that this is a wholly inappropriate, unsustainable and ill-conceived development proposal, please feel free to amend and use any (or all) of the above eleven reasons why it should be refused permission and/or add your own reasons. Submissions in your own words are best, but cut and paste submissions are better than not making your voice heard at all! Remember: your comments should be received by the Council no later than 10th February.

The next section gives step by step instructions on how to make your comments on the application.

TO OBJECT OR MAKE OTHER COMMENTS ON THE APPLICATION, YOU CAN WRITE VIA E-MAIL OR POST TO THE CASE OFFICER, MICHAEL KEMP OR YOU CAN DO SO ONLINE.

1. BY E-MAIL OR POST

The e-mail address is MKemp@oxford.gov.uk and you should include the planning reference 22/03078/FUL in your correspondence. The postal address is:FAO: Mr Michael Kemp
Planning and Regulatory Services
Oxford City Council
St Aldate’s Chambers
109-113 St Aldate’s
Oxford
OX1 1DS

2. ONLINE

STEP BY STEP INSTRUCTIONS FOR HOW TO SUBMIT AN OBJECTION OR OTHER COMMENTS ONLINE:

1. Got to www.oxford.gov.uk and this page (below) should open. Click on ‘planning’ (circled yellow at the bottom left below)
2. The next page you will see is this one (below). Click on ‘Planning Applications’) in the top left of the menu (circled yellow below)
3. The next page you will see should be this one (below). Click on ‘view and comment on planning applications’ (again circled yellow below):
4. This takes you to this page (below). Click on the big green/turquoise tab saying ‘view and comment on planning applications’ (again circled yellow below).
5. This takes you to his page (below). Insert the planning reference 22/03078/FUL into the space circled yellow below and then click on the blue ‘search’ button to the right of it.
6. The next page you see (it might take a few seconds) will be this one (below). If you want to look at the plans and reports submitted by the developer OxPlace and/or the comments other people have written, you should click on the ‘documents’ tab (circled yellow) which takes you to a list of files which you can click on to download (NB if you leave this open and inactive you will get logged out after some minutes and have to log back in again).When you are ready to make your on-line comment, click on ‘make a comment’ (circled red)
7. The ‘make a comment’ page (below) allows you to enter your name and address (this is necessary) and to register objection, support or neutrality, and to give reasons from a checklist and to scroll down to provide a written comment. It is a good idea to write your comment on a separate file (e.g. in a MS Word document) and cut and paste it into the comment box as otherwise it is easy for you to be timed out and to lose what you have written.
[1] FOIV committee also has professional consultants working on reviewing the application submission and we anticipate that more issues (and more detail on these eleven key issues) will emerge in the coming weeks. FOIV will keep people updated on developments via notices, e-mail drops and social media. Please note that you can make more than one submission to the Council – for example if you think of something you forgot to say after you’ve objected, or agree with something that emerges later.

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