HAVE YOUR SAY!
Comments to the inspector must be in before 19th DECEMBER!
The Local Plan 2031 Part 1 has been submitted by the Vale and will now be examined by an independent inspector
under the “National Planning Policy Framework” (NPPF). The full NPPF document, along with other information, is
available via a link on our website: http://www.hanneyhousingplan.co.uk/pages/information/vowhPlan.html
Paragraph 151 of the NPPF states that “Local Plans must be prepared with the objective of contributing to the
achievement of sustainable development. To this end, they should be consistent with the principles and policies set
out in this Framework”. The NPPF Ministerial Forward states “sustainable means ensuring that better lives for
ourselves don’t mean worse lives for future generations”.
Strategic sites for development have been assessed by the Vale and the results included in the “Sustainability
Appraisal” submitted as a supporting document to the Local Plan. It comprises a number of measures, most of which
appear not to be met in the case of the proposed site South of East Hanney. The EHPC sub-committee would like
you to give your view on whether the statements made by the Vale are consistent with the NPPF.
We have put together a RESPONSE PACK in which we include a copy of the form you
need to fill in, a list of possible concerns & objections you might have, and we describe
how to respond in terms that are significant for the inspector.
You may not find all the suggestions relevant to you, but they are provided for your consideration.1
Please provide your comments to the Vale, preferably in your own words…
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If you are concerned about the village and your home being adversely affected by flooding;
If you have been affected by sewage issues in the past, if you or your neighbours are already having to undertake
separate measures to control sewage and waste water, if you are concerned about sewage issues arising in the future;
If you have concerns about the damaging effects development will have on ecology, wildlife and biodiversity;
If you have concerns about extra congestion in the village and the ability of our historic roads to cope, about the
increased level of traffic on the A338, or the distances between East Hanney and any employment centres;
If you believe the consultation process was flawed in execution.
Please tell the Planning Inspectorate what you think…
RESPONSE PACKS available in the Village Shop
(or call 868823 and we will deliver to your door)
From the NPPF: The Local Plan will be examined by an independent inspector whose role is to assess whether the
plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether
it is sound. A local planning authority should submit a plan for examination which it considers is “sound” – namely
that it is:
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Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed
development and infrastructure requirements, including unmet requirements from neighbouring authorities
where it is reasonable to do so and consistent with achieving sustainable development;
Justified – the plan should be the most appropriate strategy, when considered against the reasonable
alternatives, based on proportionate evidence;
Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary
strategic priorities; and
Consistent with national policy – the plan should enable the delivery of sustainable development in accordance
with the policies in the Framework.
Response packs have been prepared by the EH Parish Council Sub-committee. If you need any help in providing your
comments or filling in the form then please call 868823 and a member of the sub-committee will help you.
Local Plan 2031- Part 1 - How to Respond2
Deadline:
All comments must be received by 4:30pm on Friday 19 December 2014
How to comment - Option 1
1.
2.
3.
4.
Print off the Publication Stage Representation form.
Fill in your details in Part A
Fill in Part B with your comments
Send by post to the Planning Policy, Vale of White Horse District Council, Benson Lane, Crowmarsh,
Wallingford, OX10 8ED.
How to comment - Option 2
1.
2.
3.
4.
Download the Publication Stage Representation form in Word document format.
Fill in your details in Part A
Fill in Part B with your comments
Email to planning.policy@whitehorsedc.gov.uk
How to comment - Option 3
1.
2.
3.
4.
Register online with a user name and password.
The vale will send back a confirmation email
Fill in your details
Add your comments and submit
How to fill in the comments sheet
This document is called:
Vale of White Horse Local Plan Part one: Strategic Sites and Policies - Public stage representation form.
Part A are your personal details
Part B Section 3. You have to state which section your comments refer to in the Local Plan. You can comment on the
local plan and any of its companion documents (Sustainability Assessment, Infrastructure Delivery Plan etc.). For the
companion documents, you should start by specifying in section 3 of the response form what you are objecting to or
supporting in the local plan itself (which comprises the main document, the appendices and the policies map).
Appendix A: Site development templates, is linked to Core Policy 4: Meeting our housing needs, the policy which
identifies the proposed housing sites.
So to comment on the East Hanney site allocation for example, enter CP4 in the policy box, and/or enter the East
Hanney housing site allocation in the proposals map box. In the body of the comment include any points you want to
make about the content of the appendices, IDP, SA or other companion document in relation to this site. You can
include more than one point in an objection so long as all the points relate to the same part of the local plan.
Section 4. askes three questions and is a simple tick box for yes or no.
Section 5. Asks you to give details of why you consider the plan is not legally compliant, unsound or fails to comply
with the duty to co-operate.
Section 6. Asks you to suggest modifications
2
© 2014 East Hanney Parish Council - local plan 2031 sub-committee
Concerns & objections you may wish to raise
If you believe, as we do, that in each of the cases below the Local Plan is not
consistent with the Vale’s principles and policies nor with those set out in the
“National Planning Policy Framework”, and the Plan is therefore “unsound”,
then please inform the Planning Inspectorate of your views.
Content
Flooding........................................................................ 3
Loss of character and village identity .......................... 5
Sewage ......................................................................... 4
Integration with the existing community .................... 6
Ecology and biodiversity .............................................. 4
Heritage ....................................................................... 6
Highways and Access ................................................... 4
Consultation ................................................................. 6
Schools and Education ................................................. 4
The underlying figures - The “SHMA” ......................... 6
Flooding
The proposed site South of East Hanney is upstream of the mill on Letcombe Brook and the development of
additional dwellings will result in an increase in the volume of water (including both run-off and water processed
from the sewerage works) being pumped into the brook, and subsequently passing through the existing settlement.
The Plan lacks any solution to management of the elevated water volumes and without a solution the risk of water
flowing into the lower fields, and flooding on to the streets of the village, will be increased. History shows East
Hanney to be a pinch point for the Letcombe Brook and this will be exacerbated by all upstream development.3
A principle of the Local Plan is to increase resilience to climate change and flooding. The site South of East Hanney
was appraised by the Vale to bring about a “neutral effect in terms of climate change and flooding. The site could
result in the loss of the best and most versatile agricultural land. The site contains a small area of flood risk.”
You may wish to challenge this statement… The comment regarding flooding would appear to be nonsense in the
face of documented evidence to the contrary. The East Hanney area is prone to flooding and the existing village has
experienced significant and damaging floods in 2007 and 2014 also, according to the Environment Agency’s "Areas
Susceptible to Ground Water Flooding" map, all of East Hanney is at the highest risk of groundwater emergence.
Development on the site South of East Hanney under current proposals will increase flood risk to the whole of the
existing settlement. Do you believe the effect will be “neutral”?
Paragraph 100 of the NPPF states that “Inappropriate development in areas at risk of flooding should be avoided by
directing development away from areas at highest risk”, Paragraph 101 states “Development should not be allocated
or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower
probability of flooding” and Paragraph 103 of the NPPF states that local planning authorities should “ensure flood
risk is not increased elsewhere”.
See also the Vale’s Core Policy 42: Flood Risk and 43: Natural Resources.
We believe the above demonstrates that inclusion of the development site South of East Hanney in the Plan
proposed by the Vale is not “consistent with national policy” as required by the NPPF, and is therefore “unsound”.
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Sewage
It is known that the sewerage works for the area are currently at capacity, giving rise to sewage issues and failures
that have already started to occur. The proposed development represents a near doubling of sewage generated
from East Hanney. Without significant investment into the upgrade of the sewerage works, in advance of
development, there will not be sufficient capacity to manage the increased levels of sewage from the new homes at
East Hanney but also those at Grove. A higher risk of exposure to sewage problems for villagers would be inevitable.
Thames water have been open in stating that they do not have the capacity or plans in place to be able to cope and
that it will take years for them to be able to address the need.4
We believe that the lack of any suitable proposal and accompanying schedule for providing a solution to the sewage
issues means the Plan is not deliverable, and so not ”effective” as required by the NPPF, and is therefore “unsound”.
Ecology and biodiversity
A principle of the Local Plan concerns natural environment, biodiversity, water and soil quality. Development of the
site South of East Hanney was appraised by the Vale to bring about a “major negative” effect in terms of the natural
environment as “an important wild life corridor” “runs alongside the Western boundary of the site” and “contains
potential UK Priority Habitat”. This is true and substantial – the site proposed indeed includes a recognised wild life
corridor along the Letcombe Brook which is known to be home to both protected and endangered species. This
diversity contributes greatly to the quality of life enjoyed by those who have chosen to live in our village yet the Vale
have appraised development of the site to have a “neutral” effect on the health and well-being of residents.
An irreversible loss of wild life is inevitable if these breeding grounds are disrupted or destroyed.
The proposal leads to the loss of a green field site, and destruction of an ancient orchard that is over 100 years old.
The Orchard site was deemed “undeliverable” in the Vale’s document Appendix 8, but is now included in the final
version of the Local Plan. How can this be?
The Vale has a legal obligation under the October 2006 Natural Environment and Rural Communities Act and has
previously made biodiversity statements and commitments. The destruction of any green field, let alone that of an
ancient orchard, seems unnecessary when alternative sites exist where the extent of loss to the natural environment
would not be so great. The Parish has offered up potentially suitable sites that include “brown field” areas.
Paragraph 9 of the NPPF document talks about “moving from a net loss of bio-diversity to achieving net gains for
nature”. Paragraph 17 states “Allocations of land for development should prefer land of lesser environmental value”.
Paragraph 109 states “The planning system should contribute to and enhance the natural and local environment by…
minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the
Government’s commitment to halt the overall decline in biodiversity”. Finally, Paragraph 118 states “planning
permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats,
including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need
for, and benefits of, the development in that location clearly outweigh the loss.” See also Core Policies 44: Landscape,
45: Green Infrastructure and 46: Conservation and Improvement of Biodiversity.
We believe that the above demonstrates that the inclusion of the development site South of East Hanney in the Plan
proposed by the Vale is not “consistent with national policy” as required by NPPF, and also not “justified” by being
“the most appropriate strategy when considered against the reasonable alternatives” and therefore “unsound”.
Schools and Education
A principle of the Local Plan is to reduce inequality, poverty and social exclusion. The site South of East Hanney was
appraised by the Vale to have good access to a primary and a secondary school. You may wish to challenge this…
The small primary school in East Hanney has exceeded its capacity with pupils from the catchment area already
facing the need to attend alternative schools, due to lack of places. There are no short term arrangements to
accommodate the additional children that are growing up in the village now, let alone those coming in from the new
development. The secondary school is actually 7.3km away and requires transport access.
The NPPF requires the Plan to be “positively prepared” by being “consistent with achieving sustainable
development”. Do you believe the above constitutes sustainable development? If not then the Plan is “unsound”.
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Highways and Access5
Traffic from the additional dwellings feeding on to the A338, both from the Grove and East Hanney development
sites, will lead to significantly increased congestion along the A338. The East Hanney development alone will attract
a further 300 to 400 cars that will need to be accommodated. Note that the previous site, proposed to the East of
East Hanney, allowed for emerging traffic to split either on to the Steventon Road towards the A34 or on to the A338
and helped to keep traffic away from the village roads that are already very busy. A principle of the Local Plan is that
residents should live near to their place of work. Development of the site South of East Hanney was appraised by the
Vale to bring about “minor positive” effects in terms that include the need to travel, and reducing road congestion.
You may wish to challenge this…
With very little employment in East Hanney, residents will be obliged to travel to a place of work elsewhere, adding
to the congestion issues and creating green house gas emissions. It takes more than an hour to travel by bus from
Hanney to Milton Park. Consideration should perhaps be given to alternative sites nearer to centres of employment.
See the Vale’s Core Policy 33: Promoting Sustainable Transport and Accessibility and 37: Design and Local
Distinctiveness
We believe that the above demonstrates that the inclusion of the development site South of East Hanney in the Plan
proposed by the Vale means it has not been “positively prepared” as it is not “consistent with achieving sustainable
development” and the Plan is therefore “unsound”, and also not “justified” by being “the most appropriate strategy
when considered against the reasonable alternatives” and therefore “unsound”.
Loss of character and village identity
The development of 200 homes will overwhelm the nature and size of the existing village with a 60% increase in the
total number of homes in East Hanney (334 homes in the 2011 Census). The imposition of a large, densely
populated estate, upon a village lacking the necessary capacity, will blight our existing community, culture, quality of
life and environment.
A principle of the Local Plan concerns availability of services. Development of the site South of East Hanney was
appraised by the Vale to bring about “minor positive” effects in terms of availability of services and facilities.
You may wish to challenge this…
Whilst the facilities score under the Vale’s assessment may suggest that East Hanney ranks as a “large village”, this is
a small community with limited services that are inadequate to support the huge proposed increase in residents. The
points scored for having a “shop” do not take into account the nature of such a tiny facility staffed purely by
community volunteers. There are no services or facilities for teenagers and young families, other than volunteer
groups. It should also be noted that the imminent loss of the mobile library will return the village to a “small”
ranking and thus would not, under the Vale’s own criteria, have warranted any such development.
10 Villages with populations greater than East Hanney and with a facilities score either the same as, or higher than,
East Hanney have NOT been earmarked for development One village in the Vale that received a facilities score of 21
and has over 1,000 homes has only been allocated a development site for 220 houses, increasing the total number of
homes by just 22% .Compare this with the almost 60% increase in homes for East Hanney.
The housing designs and styles are anticipated to be out of character with the existing settlement at East Hanney
and, with 25 homes per hectare proposed (equating to 10 per acre), so will the density.
A principle of the Local Plan is to reduce air, noise and light pollution. Development of the site South of East Hanney
was appraised by the Vale to bring about “minor negative” effects. East Hanney currently has very few street lights
and, given the scale of growth proposed, you may wish to challenge whether the negative effects will be “minor”.
Will the new development have street lights? See the Vale’s Core Policy 37: Design and Local Distinctiveness and
44: Landscape.
The NPPF requires the Plan to be “justified” by being “the most appropriate strategy when considered against the
reasonable alternatives” Do you believe this is true? If not, then the Plan is “unsound”.
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Integration with the existing community6
The proposed site extends South away from East Hanney towards Grove. Unlike the original site to the East of East
Hanney, which would have been connected by established footpaths, there are no existing pedestrian links between
the proposed site and the existing village services. The roads are narrow, constricted by the brook, without room for
new footpaths or pavements, and are of a historic nature within a conservation area. In some parts of our village
there are no footpaths.
As Grove offers far more in the way of facilities (scoring 35 as opposed to 14) the development to the South may
end up becoming closely linked with Grove and potentially better connected to it by road, foot and cycle paths - not
integral or orientated to East Hanney but divorced from the existing settlement. See the Vale’s Core Policy 37:
Design and Local Distinctiveness
The NPPF requires the Plan to be “justified” by being “the most appropriate strategy when considered against the
reasonable alternatives” Do you believe this is true? If not, then the Plan is “unsound”.
Heritage
The proposed site for modern development is South of East Hanney, adjacent to a conservation area, immediate to
some of the many listed buildings and will have a detrimental effect on their appearance and outlook. Given the
nature and density of the proposed development the character of the village will not be preserved.
Development of the site South of East Hanney was appraised by the Vale to bring about a “major negative” effect in
respect of cultural heritage and landscape. The site South of East Hanney holds some very important archaeological
artefacts including the ancient manor house of the village and a roman track/road. The opportunity for further
exploration of these artefacts, and potentially others, will be lost. Should these artefacts not be protected?
Paragraph 17 of the NPPF describes a core principle to “conserve heritage assets in a manner appropriate to their
significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations”
See also the Vale’s Core Policy 39: The Historic Environment.
There are alternative sites in the Vale without such associated history and important artefacts.
The NPPF requires the Plan to be “justified” by being “the most appropriate strategy when considered against the
reasonable alternatives”. Do you believe this is true? If not, then the Plan is “unsound”.
Any archaeological issues arising may render the Plan undeliverable, therefore not “effective” as required by the
NPPF, and therefore “unsound”.
Consultation
The consultation in Spring 2014 was undertaken with reference to a single site to the East of East Hanney. The
switch, sometime after the consultation period, to an alternative site South of East Hanney appears to the residents
to be unexplained, unsubstantiated, unsupported and illogical. This alternative site has not been the subject of any
proper resident consultation or consideration. Research undertaken by the sub-committee has shown that the
South siteis not the preferred choice of the community.
Section 17 of the NPPF lays out a set of core planning principles, the first talks about “empowering local people to
shape their surroundings”. Do you believe this has been the case?
The NPPF requires the Plan to be prepared “in accordance with legal and procedural requirements”. If you believe
the consultation process was flawed in execution then tell the Inspectorate you believe the Plan is “unsound”.
The underlying figures - The “SHMA”
The Strategic Housing Market Assessment has been used as the justification for additional housing specified in the
Local Plan. The SHMA is being widely reported as discredited with the requirement for increased housing overstated. The basis upon which East Hanney has been deemed to require additional housing is therefore questionable.
The NPPF requires the Plan to be “positively prepared” by being based on a “strategy which seeks to meet
objectively assessed development and infrastructure requirements”. Do you believe that the SHMA figures represent
objectively assessed requirements? If not, then the Plan is “unsound”.
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Relevant Extracts from the Vale’s Core Policies
The Vale has listed 47 Core Policies – see page 2 of the first chapter of the Local Plan. We have extracted
just some of the relevant sections below, but there are others.
Please see the Local Plan for the full text of those quoted below.
Most of our residents’ comments should be addressed as relating to Core Policy 4.
Core Policy 4 appears in Chapter 4 of the Local Plan 2031 Part 1. The rest appear in Chapter 6.
Core Policy 4: Meeting our Housing Needs
The housing target for the Vale of White Horse District Council is for at least 20,560 homes to be delivered in the
plan period between 2011 and 2031. 13,960 dwellings will be delivered through strategic allocations. 1,900 dwellings
remain to be identified and will be allocated through the Local Plan 2031 Part 2 or Neighbourhood Development
Plans or through the Development Management Process. The contribution of all sources of housing supply are
shown by the following table.
A table is then included detailing East Hanney under Settlement/Parish, Larger Village under Settlement Type,
South of East Hanney under Site Name and 200 under Number of Dwellings.
Core Policy 33: Promoting Sustainable Transport and Accessibility
The Council will work with Oxfordshire County Council and others to:
 actively seek to ensure that the impacts of new development on the strategic and local road network are
minimised
 ensure that developments are designed in a way to promote sustainable transport access both within new sites,
and linking with surrounding facilities and employment
 ensure that transport improvements are designed to minimise any effects on the amenities of the surrounding
area
 promote and support improvements to the transport network that increase safety, improve air quality and/or
make our towns and villages more attractive.
Core Policy 37: Design and Local Distinctiveness (Local Plan Chapter 6)
All proposals for new development will be expected to be of high quality design that:
 responds positively to the site and its surroundings, cultural diversity and history and reinforces local identity or
establishes a distinct identity whilst not preventing innovative responses to context
 creates a distinctive sense of place through high quality townscape and landscaping that physically and visually
integrates with its surroundings
 is well connected to provide safe and convenient ease of movement by all users, ensuring that the needs of
vehicular traffic does not dominate at the expense of other modes of transport including pedestrians and
cyclists, or undermine the resulting quality of places
 incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet
recreational needs including Public Rights of Way
 is visually attractive and the scale, height, density, grain, massing, type, details and materials are appropriate for
the site and surrounding area
 is sustainable and resilient to climate change by taking into account landform, layout, building orientation,
massing and landscaping to minimise energy consumption and mitigate water run-off and flood risks.
Core Policy 39: The Historic Environment
The Council will work with landowners, developers, the community, English Heritage and other stakeholders to:
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ensure that new development conserves, and where possible enhances, heritage assets and their setting in
accordance with national guidance
better understand the significance of Conservation Areas in the district
Core Policy 42: Flood Risk
…seeks to ensure that development provides appropriate measures for the management of surface water as an
essential element of reducing future flood risk to both the site and its surroundings.
The risk and impact of flooding will be minimised through:
• directing new development to areas with the lowest probability of flooding…
• ensuring that development does not increase the risk of flooding elsewhere…
The suitability of development proposed in flood zones will be strictly assessed.
Core Policy 43: Natural Resources
All development proposals will be required to make provision for the effective use of natural resources where
applicable, including:
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causing no deterioration in, and where possible, achieving improvements in water quality
ensuring that the land is of a suitable quality for development
avoiding the development of the best and most versatile agricultural land, unless it is demonstrated to be the
most sustainable choice from reasonable alternatives, by first using areas of poorer quality land in preference to
that of a higher quality, and
re-using previously developed land provided it is not of high environmental value.
Core Policy 44: Landscape
The key features that contribute to the nature and quality of the Vale of White Horse District’s landscape will be
protected from harmful development and where possible enhanced, in particular:
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features such as trees, hedgerows, woodland, field boundaries, watercourses and water bodies
areas or features of cultural and historic value
tranquillity and the need to protect against intrusion from light pollution, noise, and motion.
Core Policy 45: Green Infrastructure
A net loss of Green Infrastructure, including biodiversity, through development proposals will be resisted.
Core Policy 46: Conservation and Improvement of Biodiversity
Development that will conserve, restore and enhance biodiversity in the district will be permitted. Opportunities for
biodiversity gain, including the connection of sites, large-scale habitat restoration, enhancement and habitat recreation will be actively sought, with a primary focus on delivery in the Conservation Target Areas. A net loss of
biodiversity will be avoided.
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….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 habitats and species of importance to biodiversity and sites of geological interest
considered include Local Wildlife Sites, Priority Habitats and veteran trees.