FOIV’s response to the second OCHL consultation
To OCHL
4th January 2022
Friends of Iffley Village Comments on OCHL’s second public consultation.
Friends of Iffley Village (FOIV) is the residents’ group for anyone who lives in Iffley or has an association with the village. The organisation is run by its management committee, which deals with matters arising such as proposed developments, parking, and other local issues. It also organises events during the year. Although it has no formal role in connection with the Oxford City Council, it is usually consulted in matters relating to planning decisions. In a recent survey of its membership (currently 361 members), 78% of respondents were in favour of keeping the Horse Fields green, and 81% said that the proposed development would have a negative impact on the Quiet Route.
We offer the comments below without prejudice to our position that we are opposed to the proposed development of the Horse Fields (‘Land off Meadow Lane’, SP42), and indeed that failures in the site allocation process mean that they should not have been allocated in the first place.
Key areas of local concern:
1. Ecology and biodiversity
2. Conservation Area: rural characteristics, open space, green infrastructure
3. Traffic and parking
4. Quiet Route: cycling, pedestrians, equestrians
5. Flood risk and drainage
6. Design
7. Lack of accuracy and coherence in public communication and consultation
Page numbers refer to the PDF version of material, online at: https://consultwithyou.co.uk/ochl/iffley/proposals#nav
1. Ecology and biodiversity
1.1 We agree with the statement on p. 10 of the printed material that ‘the existing ecology and landscaping is key’; however the information provided does not indicate how this development would protect or enhance existing ecology and landscape values. As indicated on the Masterplan (p. 5), the siting of access road, footpaths, and substantial gardens indicate minimal concern for the site’s existing ecology.
1.2 We are concerned about the ecology and habitats found on the two fields themselves, and not just the boundaries (hedgerow on Meadow Lane and stone wall on Church Way). We look forward to reading your analysis of the ecology of the site and precisely how you propose to achieve a biodiversity net gain of 10% in line with the Environment Act 2021 on the Horse Fields as net loss presently appears more likely. We anticipate further studies of the potential impacts on the nearby SSSI, as required by the Local Plan. This should include demonstration of how the development will achieve, in isolation and cumulatively, a nutrient neutral position in order to avoid exacerbating nitrogen and phosphate pollution on Iffley Meadows SSSI or other downstream flood meadows.
1.3 We look forward to understanding how you propose to protect the wildlife living on the Horse Fields and the wildlife corridors to adjacent green and blue spaces. We have yet to be convinced that you have conducted adequate surveys for all likely protected species, and have fully considered the implications of the loss of their habitat and foraging areas.
1.4 We remain deeply concerned about the safety of the large, resident badger population in these fields. Inconsistent responses from the OCHL team, as well as the indicative design, has only intensified our concern for their future. As well as threat to the sett, no regard appears to have been had for their foraging requirements.
1.5 We question why Memorial Field is being included in this development proposal (p. 11), not being part of the allocation SP42? Urgent clarity is sought on this point. If there is an intention to appropriate Memorial Field for delivery of open space, biodiversity and other elements then we consider this will not be compliant with the Local Plan. If, alternatively, proposals for Memorial Field are purely enhancement (i.e. not mitigation or compensation) then far greater information is needed in order to reflect on a management plan for Memorial Field.
2. Conservation Area: rural characteristics, open space, green infrastructure
2.1 The development appears inconsistent with the ‘sensitive infill’ recommended in the Local Plan. The proposed natural areas and community open spaces appear extremely small in relation to the built environment.
2.2 The proposed development fails to conserve and protect the ‘strong rural characteristics’ identified as a key feature in the Iffley Conservation Area Appraisal (2009) and in fact will deliver very substantial harm to these assets. These last remaining open fields are what preserve the unique, rural character of Iffley described in the ICA. This harm applies to views into and out of the ICA as well as the integral fabric of the ICA itself.
2.3 The lower half of Meadow Lane, with its grass verges and intermittent open views through the established hedgerow, currently retains the feel of a rural country lane, deriving from its historical, medieval origins as a drover’s lane. This will be lost to the detriment of the ICA.
2.4 The Horse Fields gate on Church Way provides the first open green views for pedestrians approaching the village from Iffley Turn, and down the hill from Tree Lane. These views, towards the river and undeveloped floodplain, are key to maintaining the essentially still rural setting of the village and by extension the integrity of the ICA. The current design proposes four houses that will entirely block these existing rural views as well as the associated wildlife corridor.
2.5 Equally, there is no consideration of substantial harm that will be caused to the views from the riverside tow path through undeveloped fields to the historic built fabric of the ICA, visible as rooflines behind the open edge-of-village small fields represented by the Horse Fields and Memorial Field. This is a serious omission.
2.6 The visualisation of street scenes depicted on p. 7 bears no relation to the character of the Iffley Conservation Area. The views portrayed in the cross-section drawings, on the same page, do not reflect actual views from either Meadow Lane or Church Way.
2.7 We would argue strongly for the preservation of the hedgerow along the lower half of Meadow Lane. We note the proposal, on p. 10, to create a thick hedge, while on p. 2, the visualisation suggests the hedgerow will be entirely removed. We welcome the proposals for retaining and enriching the existing hedgerow, but we seek reassurance that its height and rural character will be preserved. Clarity is sought on this design point.
3. Traffic and parking
3.1 We understand that a one-way flow of traffic, with entry on Church Way, has been considered and rejected. In our view, the choice of a two-way traffic flow onto Meadow Lane introduces serious problems as well. Meadow Lane is not wide enough to accommodate parking as well as a steep increase in two-way traffic. The lane would be constantly clogged, making it inhospitable for pedestrians, cyclists, equestrians, and mobility scooters. The junction of Meadow Lane and Church Way, already hazardous at times, would be frequently dangerous, especially to the residents of Lucas and Remy place and users of the Quiet Route. The proposed entrance/exit to the development offers low visibility at the bend in Meadow Lane.
3.2 The turning space provided for the two proposed houses off Church Way is likely to be filled with visitor cars, or a second resident car, which would lead to blocked cars dangerously backing onto Church Way, already congested with traffic.
3.3 Given the traffic constraints of the village’s narrow lanes, if there is to be housing on the Horse Fields, we would advocate for a totally car-free development (a genuine one, not just one in name only) with adequate car-sharing facilities. We recognise, however, that this is not a realistic option, given that many residents will opt to own a car, especially as the closest shopping facilities are at the Cowley Centre. If cars must be integrated into the development, we think parking space should be made available for all residents within the site. Otherwise, they will end up parking in Meadow Lane and elsewhere on crowded village lanes.
3.4 While we welcome the City and Council Council’s aims to reduce car usage, we remain wholly unconvinced (not least due to the lack of any supporting evidence) that reducing available parking spaces on this site will lead to a reduction in car ownership or use. Is there any evidence to demonstrate that this works in practice? How have you arrived at the number of 12 spaces for 30 homes and some 130 people?
3.5 OCHL states, on p. 6, as well as in an individual response to FOIV Committee, that they will ‘actively promote sustainable modes of travel’ and that they ‘are encouraging residents to use more green modes of travel’. We would like further information about what is being done to promote this modal change. In any case, we find totally unconvincing the claim on p. 12 that the reduction will help ‘to ensure that the overall rural character of Iffley is maintained’.
3.6 In the current proposal, why are the wealthy residents in market-priced homes being given parking priority over those in social housing? Is there any evidence that the less well-off have less pressing need for a car?
3.7 Currently, limited-scale parking on Meadow Lane is predominantly by care-workers looking after residents in Lucas and Remy Place. We believe that the current proposal will result in those spaces being taken up instead by residents of the proposed development.
3.8 The present design seems to provide only one hook up point for an electric vehicle. Given the government’s policies on shifting to electric vehicles, why are electric hook up points not being provided for all dwellings as standard?
4. Quiet Route: cycling, pedestrians, equestrians
4.1 Meadow Lane is currently part of a designated County Council Quiet Route, heavily used by cyclists, joggers, walkers, families with prams, mobility scooters, and horse-riders. We look forward to seeing what surveys you have undertaken of these existing user-communities of interest using the Quiet Route. Local residents of Meadow Lane have undertaken their own survey of the Quiet Route in 2020, and would be happy to share their findings with the design team.
4.2 On p. 6, you claim to be ‘encouraging residents to use more green modes of travel’. As a principle, we welcome this as an overall objective but there is a dearth of confidence that it will be achieved by the proposals as so far seen. For example, we have commented above on the parking matters and the purported ‘car free’ objective. One other measure proposed on p. 9 to ‘encourage sustainable travel’ is the creation of ‘a new foot and permissive cycle route from the site to Meadow Lane and Church Way’. Elsewhere in the printed material, however, the path through the development as a ‘pedestrian link’, not a new cycle route (p. 5).
4.3 We are confused as to what is actually being proposed to encourage cycling and active travel, and linking Meadow Lane and Church Way. For example, who are the intended users of the pedestrian path proposed behind the hedgerow on Meadow Lane?
5. Flood risk and drainage
5.1 As this site is on the edge of the Flood Plain, OCHL have written they will ‘mitigate’ the increased flood risk by introducing ‘sustainable drainage features including rain gardens and tree pits’ (p. 10) and that SUDS measures will be introduced to mitigate the harmful effects of the development (p. 4). No one at the Open Day was able to provide answers to our concerns about the underlying geology, lowish soil permeability and ground water levels on this sloping site, in addition to the mains drains proposed. Nor do the space requirements for effective SUDS appear to have been given proper consideration. We are not yet convinced that measures stated will deal with drainage and waste water issues, including in relation to the potential for raw sewage discharges into the river during extreme weather events forecast in the climate emergency (see also above in relation to nitrogen and phosphate pollution). We look forward to scrutinising the flood risk and drainage strategy reports to be published with the planning application. And we seek reassurance that OCHL have considered the future impact of climate change.
5.2 The map on p. 4 clearly indicates that the Horse Fields currently mitigate flood risk. How will this be sustained once the fields have been in large part laid to concrete or other hard surfaces? What provisions are OHCL making to manage the ditch and stream at the foot of the Horse Fields, both as a carrier, attenuation feature and at the same time maintaining its existing biodiversity interest?
5.3 Do the drainage and flood mitigation plans meet the requirements of insurers so that owners of the new properties will be able to obtain comprehensive building insurance?
6. Design
6.1 As discussed above, we fail to understand how a scheme design that protects and enhances the Iffley Conservation Area can be delivered, given that the proposal destroys fields that specifically contribute to the rural character of the ICA. We believe there is an inherent and irreconcilable conflict within the Local Plan policy on this matter and that this goes to the point that insufficient work was done to assess this site’s suitability for development prior to it being allocated.
6.2 Is this a landscape-led design aimed at maintaining the existing rural character of the fields and lanes? Or is the design aiming to match the existing built environment in the Iffley Conservation Area? The current plan is unclear with regard to these questions. If the former, the design proposal does nothing to preserve the rural characteristics of the ICA. If the latter is your aim, please consider taking as your ‘local vernacular’ referent, the historic, 2-storey social housing on Church Way, built of Cotswold stone:
6.3 The visualisations on p. 7 of ‘sensitively designed’ homes that will ‘complement the existing village vernacular and Iffley Conservation Area’ bear no relation to existing buildings in the ICA, in their open, rural setting. They appear to us generic designs that could be lifted from any new suburban development, and are in no way in keeping with the character of the Iffley Conservation Area. The specific Iffley Village architectural cues that the design stems from should be articulated and the design rationale fully explained.
6.4 If there is to be departure from the local vernacular (e.g. to respond to landscape concerns by using design features to try and ‘hide’ the development), then we would expect to see imaginative use of excavation to dig homes into the slope to preserve the view from Church Way, use of green roofs, traditional street lighting, use of Cotswold stone for house facing and garden walls, rural and ragged edging within the development, as well as along Meadow Lane and Church Way, with narrow entrance ways preserved.
6.5 The proposed rooms-in-the-roof of the majority of the houses look more like three storeys than the stipulated limit of two storeys. The visualisation on p. 2 renders the roofs in a colour that blends with the sky, which seems designed to downplay the actual height of the proposed buildings. Please advise on the actual ridge heights in the plans. 2.5 storeys is not the same as 2 storeys.
6.6 On p. 8, OCHL claim, ‘We are committed to delivering a sustainable scheme and want to set the standard for new housing as the City works to tackle the climate emergency’. We welcome this commitment, but seek clarification on how the present design delivers on these words. How will all the new-builds be designed and built to minimise total energy use? Can you explain the mix of solar provision and Passivhaus design? From the printed material, it seems that only affordable homes will be built to Passivhaus energy standard. If this is the case, why?
6.7 We welcome the commitment to Passivhaus energy design but would ask why this is framed as a vague commitment rather than an objective to be achieved and confirmed through certification. Why are you not requiring certification of Passivhaus energy standard?
6.8 What specific targets are OCHL giving the builders in terms of energy consumption in the homes for heating and hot water?how will you certify that the designs will attain these targets?
6.9 The written material sets out OCHL objectives of providing affordable housing in Oxford and asserts that it takes this objective seriously while commercial developers would not do so. However, the SP42 policy for affordable housing is the same as for all developments under the Local Plan 2036, i.e. making provision for 50% affordable and social housing. The current design for this development goes no further than the minimum required in LP2036, making provision for 12 homes at social rent. Please explain how this is going further than any other commercial developer. The Masterplan (p. 5) suggests that most of the area is given over to luxury market value homes with relatively large suburban gardens. Could the developers indicate how the intended design will foster community cohesion and integration of lower and high value homes? Could OHCL confirm that the net profit from the development will be ring-fenced for affordable housing delivery elsewhere in Oxford? We were advised at the public meeting that it would merely be returned to OCC’s coffers and could thus be spent on things other than social housing. This seems wrong.
6.10 Could OCHL provide information on how the development on the Horse Fields will help address Oxford’s problems with housing affordability. Is there a target for the intended pricing across the 30 housing units? Will the average sale price across the 30 units be lower than the Oxford City average or higher?
6.11 Could OCHL indicate its proposal for how communal natural areas of the site plan will be maintained and managed given the mix of private and public holdings?
6.12 Have you calculated the carbon release of the construction process? Hill has stated a commitment to becoming a zero carbon builder by 2030. This does not provide any assurance for the zero carbon build target for this particular development proposal.
7. Lack of accuracy and coherence in public communication and consultation
7.1 We welcome the opportunity we were given to meet with the design team on 11 December. We are disappointed, however, by the incompleteness, inaccuracy and inconsistency of the information supplied by different members of the team to different members of FOIV and the general public. There are also discrepancies between what we were told by the design team and what is included in the written material. The written material itself contains numerous inaccuracies and inconsistencies from one part of the document to the next.
7.2 For example, the hedgerow at the bottom of Meadow Lane is either to be preserved, re-laid or removed, according to different sections of the document, and different statements by the design team. In the printed material, the visualisation on p. 2 of Meadow Lane is extremely misleading, suggesting a wide avenue, with new landscaped frontage and no hedgerow. This is not consistent with the description of the same, on p. 10. The extensive badger sett is either to be preserved or re-located, according to different statements, while the site plan on p. 5 sites a public footpath right through the existing sett location. The photos on p. 10 (of fritillaries, beehives, tree pits and a suburban street) appear to bear no relation to the textual description of the site plans. The half-timber buildings and traffic calming measures pictured on p. 9 appear to bear no relation to the design proposals for this site. The photo captioned ‘Iffley meadow fritillaries’ actually shows green winged orchids, a base error that suggests the PR team are making decisions on publicity material based on what they think will play well rather than what they know to be accurate. This is extremely alarming.
7.3 References to the Memorial Field in the written document (p. 11 and elsewhere) are confusing and seem to suggest that the Horse Fields development is being traded off against the Memorial Field. This is not what is stated in the Local Plan allocation of this site.
7.4 The Horse Fields and the Memorial Field are entirely separate issues. The Memorial Field should be the subject of a separate consultation. Consultation over the Memorial Field should be informed by appropriate studies and information on possible long-term institutional arrangements that will help secure its protection for the long-term.
We look forward to receiving your response.
Best wishes
Ms Troth Wells
Chair, Friends of Iffley Village
10 Tree Lane
Iffley
Oxford OX4 4EY
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