ANNEX A

Summary of main points from consultation responses

Just over 2,690 individuals and organisations made comments on the draft Plan, including approximately 100 local councils, 100 consultees including the five district councils, 50 local business and commercial interests, 50 other local groups and organisations, 70 developers and landowners and 2,300 members of the public. Most of the responses received were concerned with two major issues – a) the proposed development in the Green Belt south of Grenoble Road, Oxford and b) the proposed new strategic area for sand and gravel extraction in South Oxfordshire. 

Approximately 1,900 objections were received regarding the proposed development south of Oxford. These included just over 1,100 standard objections from three separate organisations. Summaries of these are included under Chapter 7 – Policy H1.

Other major areas of comment were on other areas of the development strategy and housing distribution, the economy, transport and affordable housing.

This annex sets out the main comments received on the strategy and policies in the draft Plan. Apart from comments on Chapter 2 (Strategy), comments made on the supporting text in the Plan have not been included.
 
For ease of reference the annex is organised in the order of the chapters in the deposit draft Structure Plan. For most chapters summaries are included by policy, except where comments were less detailed. A summary of the main comments relating to alternative development proposals at Shipton-on-Cherwell Quarry and the proposed ‘Penbridge’ village at Sunningwell are included at the end of this annex.

Chapter 1 – Introduction 

Comments on the introduction included the following:

•	Plan should provide fuller account of reasons for the review, the success or otherwise of adopted Plan strategy and previous Plan 
•	No indication of how plan will be monitored and the need to refer to county’s importance as a centre of culture and for quality of environment (English Heritage)
•	Amend Plan so that it will be clear how the plan is to be implemented and monitored and refer to carrying out of sustainability assessment (GOSE)
•	Inadequate justification for what appears to be a continuation of the Country Towns strategy
•	Insufficient justification, lack of planned positive action. Plan is too Oxford centred (CPRE)
•	A need to refer to links to surrounding areas e.g. Milton Keynes and Western Corridor (ACTVaR )
•	Underplays the importance of Oxford’s institutions and others outside Oxford City
•	Welcome reference to Oxfordshire Community Partnership – important that Plan becomes spatial arm of LSP/Community Plan (GOSE)
•	Comments were received in support of the aims and objectives (e.g. Cherwell DC and English Nature) 
•	Suggested amendments to the aims included: protection of environment should be given greater prominence, upgrade aim 4 on economy (e.g. UKAEA ,Defence Estates), farming should be further emphasised in the aims and objectives (Country Land and Business Association)
•	Aims should be those in the Community Strategy (GOSE)

Chapter 2 – A strategy for Oxfordshire

Comments on the strategy generally focused on the following two areas - the strategy to 2016 and the strategy Post 2016.

(a)	General strategy to 2016

•	Welcome that Cherwell’s allocation has fallen to reflect concerns about capacity (Cherwell DC)
•	Insufficient emphasis given to Oxford in accommodating needs, question whether plan goes far enough in addressing potential of the sub region; should change to accommodate significant amount of development close to Oxford
•	Policy of restraint could seriously damage economy of the sub region. Object to restraint on employment in Oxford – promote greater employment provision in the country towns and other locations
•	Oxford must be considered more clearly in context of hinterland – conduct systematic search for locations close to city; Shipton has major advantages over Grenoble Road
•	No clear link between development at Oxford and Grove and aims and objectives (Vale of White Horse DC)
•	Oxford and Grove proposals should not be firm until proper Strategic Environmental Assessment has been carried out
•	Strong reservations about draft Plan proposals along the A34 – need to develop non trunk road solutions as part of LTP process (Highways Agency)
•	Support the focus on larger towns, apart from Green Belt development
•	Support development west of Didcot to 2016
•	Refer to potential in Kidlingotn/Yarnton/Begbroke area - should be identified for mixed development with emphasis on high tech commercial sector
•	Consider that Witney has no further capacity – particularly in advance of improvements to public transport
•	Welcome recognition of role of smaller towns – but need development which respects character of settlements
•	Failure to consider the potential or recognise the role of smaller towns e.g. Kidlington, Henley-on-Thames, Chipping Norton, Thame, Carterton
•	Previously developed land target - why is it lower than government target? Should be minimum and more inline with Government target of 60%

Development south of Grenoble Road:

•	Object to the proposed development south of Grenoble Road, Oxford for reasons given under Policy H1 
•	Support Grenoble Road, is the most appropriate way to meet housing shortages 
•	Include new policy for localised review of Green Belt around market towns where safeguarded land can be identified

Berinsfield:

•	Development at Berinsfield is supported – increase South Oxfordshire provision by 500. Could benefit from additional facilities, services and would address problems with housing mix
•	Object to the proposed development at Berinsfield (including South Oxfordshire DC and Berinsfield Parish Council) - no exceptional circumstances identified, development inappropriate, not viable and would encourage car use; not a strategic allocation 
•	Welcome review of Green Belt in South Oxon. Object to limitation to Berinsfield - extend especially to area around Wheatley

Grove:

•	Object to the proposed development at Grove, reasons include: area is not sustainable, few job opportunities, scale of provision is out of proportion to housing need, job growth potential and linkages to employment centres, traffic impact on villages east of Grove and impact on A34, flooding (nothing done to control run off due to past growth), road improvements seldom carried out, nothing to say there will be improved services and infrastructure, could lead to significant commuting, amount of housing should be reduced,  commitment in Local Plan does not justify scale, Shipton Quarry is more sustainable (is in a transport corridor, could achieve environmental improvements as at Upper Heyford)
•	Support the proposed development at Grove - on condition that it has all associated facilities and infrastructure. Unrealistic to have all transport improvements before any development is occupied, scheme will have to be phased
•	Advocate site to north of Grove – use for mixed development and to strengthen economic base
•	Development at Grove must be conditional on railway station being open
•	Make clearer how major development at Grove is consistent with aims and objectives of the plan and strategy (Vale of White Horse DC)

(b)	Development Post 2016 

•	Must propose a single strategy based on rigorous assessment of the issues and alternatives (Vale of White Horse DC)
•	Any statement for post 2016 must be appropriate and provide realistic guidance
•	Premature to give guidance post 2016 - no statutory weight. Should not predetermine or prejudge the Regional Spatial Strategy (Oxford City and others)
•	Object to Bicester, Didcot, and Grove – likely Plan will become redundant. Thame should be considered, object to exclusion of Banbury
•	Should indicate the role of Oxford to continue as major centre, to maintain and enhance position as `vibrant and prosperous city’

Bicester:

•	Delete reference to Bicester post 2016. Is struggling to cope with current planned development, will necessitate dramatic changes in road system, town has become a dormitory, concerns about extra commuting to Oxford – prefer modest development in larger villages
•	Support stance that there should be no more development in Bicester until improvements in infrastructure 
•	Object to proposed development at Bicester - is difficult to achieve perimeter road, town centre not mentioned as location for large scale retail/leisure, no mention of transport implications, town has large scale out commuting (Cherwell DC)

Didcot:

•	Object to identification of Didcot post 2016 for the following reasons: lack of transport and other infrastructure, current resources are at capacity and infrastructure cannot support current and planned developments, will make major congestion worse, no further development without A34/A40 upgrade, the town needs time to absorb development and to achieve a balance, does not allow for consolidation of the community and improvement to social fabric,  local employment is not sufficient, ignores environmental constraints, development is absorbing buffer between town and neighbouring villages and could destroy the countryside
•	Progress on issues relating to the A34 and wider strategic network including rail must be made before any growth can be considered at Didcot post 2016 (South Oxfordshire DC)
•	Broadly agree with further growth for Didcot but further development depends on satisfactory investment in the A34 corridor (Vale of White Horse DC)
•	Support development at Didcot. Should not preclude land to north coming forward more quickly, develop to the west - no significant constraints

Grove:

•	Support development at Grove post 2016 but there is no reference to further long term potential, could deliver a new transport route between Grove airfield, the A338 and A417

Witney and Carterton:

•	Delete reference to further growth at Witney and Carterton post 2016 in absence of planned infrastructure improvements to address deficiencies (West Oxfordshire DC)
•	Object to assumption that Witney has good public transport. Why is A40 strategy not mentioned until post 2016 section? 
•	No further housing in Witney and surrounding areas until necessary roads, infrastructure and link roads have been constructed

A New Community beyond the Green Belt

•	There were few representations in support of a new community 
•	Bring the idea for a new community into discussion for current plan period 
•	Object to the reference to a new community for reasons including: prejudges  the issue, no national or regional policy support, would divert investment from the country towns, there are more sustainable locations e.g. Grove, Banbury, Didcot, urban extension to Oxford

Reference to not releasing land in the Green Belt except for development proposed south of Grenoble Road (paragraph 2.23): 

•	Partial review of Green Belt needed now - full review post 2016 
•	Inappropriate to predetermine future need to release Green Belt, should refer to need for critical review to identify most sustainable forms of development
•	Inappropriate to speculate about potential needs. Should address post 2016 by preparing ground for strategy which will deal more effectively with relationship between housing and employment
•	Need more explanation of why this strategy is justified

Chapter 3 – General policies for development

Comments on the general policies included the following:

Policy G1:

•	Object to “restraining the overall level of development” 
•	Provide a clear commitment to sustainable development 
•	Plan makes no comparative assessment of the main settlements 
•	Identify which larger urban areas will be the main focus - include Witney, Bicester, Didcot and Banbury, areas adjoining Oxford such as Kidlington
•	Too heavily favours development in larger urban areas – add major developed employment sites that support existing and emerging growth sectors and clusters
•	Smaller towns and larger villages should be identified as locations for additional growth, permit new housing in smaller villages where there are sustainable modes of transport
•	Should include a specific statement about avoiding coalescence of settlements and protecting the character of towns and villages
•	Should give priority to making best use of previously developed land (Vale of White Horse DC)
•	Recognise that sustainable development can be appropriate outside the urban areas where previously developed land is available 
•	Refer to providing sufficient affordable housing to meet current and future needs
•	Make clear impetus to minimise use of greenfield land and requirement for sequential analysis for competing greenfield sites

Policy G2:

•	G2 a) is restrictive – replace “appropriate to the site and its surroundings “with “appropriate to meet identified needs”
•	Include positive statements to say new buildings for farms and diversified enterprises will normally be permitted in an existing complex or other well screened locations
•	All developments should reduce car use – amend policy to preclude developments that do not 

Policy G3:

•	Policy is negatively worded – delete “cumulative impact”, reword to state proposals will be permitted provided they provide infrastructure and services to a level appropriate to the development
•	Clarify that only contributions to infrastructure requirements which are necessary, relevant to planning, directly relevant to the proposed development, fairly and reasonably related in scale and kind to the development and phased to come forward as development proceeds will be sought from developers 
•	Need flexibility in calculating contributions and take level of affordable housing into account
•	Relying on developer contributions leads to late provision of infrastructure. County Council is responsible for many of these functions; ensure capital programme is geared to meeting needs of development proposed - particularly where there are current deficiencies. New development should not be expected to make good existing deficiencies 
•	Affordable housing should be top priority for contributions
•	Infrastructure should not be provided on a phased basis – provide before development takes place
•	Local authorities may not always be the decision maker – policy should be clear and precise - phrases like “will be resisted” and  “ will be welcomed” may not provide sufficient certainty to landowners, developers or the public about how an application may be determined (GOSE)

Policy G4:

•	If Green Belt is to be lost, land of the same area and quality should be designated. Indicate in general terms compensatory areas of Green Belt to be added if development at Grenoble Road is implemented (GOSE)
•	The policy is inconsistent with the urban extension at Grenoble Road. Amend to reflect that development is proposed in the Green Belt
•	Should have undertaken a comprehensive Green Belt review - do not proceed until carried out. If Green Belt review is to be carried out it should be in a systematic and considered manner. Establish permanent boundaries that will endure and enable land to be released for development
•	Comprehensive review of the Green Belt is neither appropriate nor necessary – introduce new policy to specifically allow for review of the green belt boundary at Grenoble Road
•	Need review of designations and redefinition of its boundaries. Consider sites which no longer conform to the ideal e.g. review area around Kidlington; permit large scale development south of Oxford to create a sustainable community, and sites such as Wheatley, where development has weakened the Green Belt 
•	More flexible wording needed, which would allow for development where there are obvious policy advantages e.g. Shipton Quarry. Reflect opportunities for small scale amendments for local developments; refer to likelihood of small scale Green Belt review at Cowley in order to allow expansion of BMW complex
•	Policy should state that Green Belt cannot remain immune from events occurring in the rural economy - allow for agricultural diversification, employment, social housing and tourist and recreational facilities (Country Land and Business Association)
•	Object to statement about park and` ride sites as exceptions
•	Refer to meeting essential needs of Oxford’s high tech industries as exceptions

Policy G5:

•	Policy is too restrictive (SEERA). Appears more restrictive than the Green Belt policy (GOSE )
•	Reference to development in the vicinity of motorway or major road junctions will not be allowed should be reinstated as in adopted policy
•	Supporting text is unnecessarily restrictive in not allowing development in the vicinity of a major road junction - development must be promoted in the optimum location
•	Policy needs to refer to rural exception sites being appropriate for affordable housing
•	Amend to say development will be permitted where sustainable communities can be sited to take pressure off existing villages and rural roads
•	Concerned that the policy might stifle the wider rural economy (Country Land and Business Association)
•	Plan should allow reuse of major developed sites beyond urban areas in sustainable locations

Policy G6:

•	Object to the perception that minerals extraction causes environmental harm. The statement environmental harm caused by mineral extraction needs to be qualified (Quarry Products Association)
•	Policy is unduly onerous - refer to developments where appropriate, of an appropriate scale and type. Should be more flexible and say encouragement will be given

Chapter 4 – Transport

The comments on transport matters included the following:

•	The introduction to the transport chapter should show how the policies will satisfy Government advice, in PPG13 especially, how they take forward the Regional Transport Strategy, and how they relate to the land use spatial strategy
•	Give greater emphasis to car use (especially in rural areas)
•	Should give priority to sustainable travel modes, car use should be restrained
•	Some of the places identified for housing in the Plan are not good locations for sustainable transport. There should be a policy giving priority to more sustainable locations
•	Importance of integrated land use planning to reduce the need to travel
•	Policy should include the requirement for Travel Plans
•	There is a mismatch between the county transport system and proposals for development, particularly in the lack of road capacity, so there is incompatibility between policies T6 and T8
•	Should be more car parking in various suggested locations, e.g. hospitals, rail stations
•	Car parking standards should be included and with criteria for new Park and Ride provision
•	Further Park and Ride expansion at Oxford opposed 
•	Town centres face competition caused by free parking at edge of town retail parks
•	Encourage use of powered two–wheelers through free parking
•	Greater priority should be given to the development of the public transport network and the premium bus network should be extended
•	Premium bus network should have orbital routes (especially Wantage/ Milton Park/ Wallingford), not just Oxford radial routes
•	New rail stations needed, especially at Grove and Kidlington
•	The freight policy should include water transport
•	Lorry routing policies are needed
•	Lack of policy for air travel facilities and for provision of freight operational services
•	Should be separate policies for walking and cycling
•	More positive discrimination needed in favour of walking and cycling
•	Dependence/importance of A34 Multi Modal Study outcomes to proposed developments and Oxfordshire networks
•	Policy T6 needs to define the transport networks and list the strategic transport schemes that will be implemented during the period of the Plan
•	Various suggestions for major road construction schemes
•	Add reference to overnight lorry parks serving M40 and A34
•	Requirements in policy T8, Development Control, need to be firmer; should include guidance on providing transport assessments

Chapter 5 – Protecting and enhancing the environment

Comments on protecting and enhancing the environment included the following:

•	A number of new policies were suggested, including: reducing noise and light pollution (CPRE Oxfordshire) and supporting climate change mitigation
•	Policy EN1 should not require development to protect, maintain and enhance environment. PPG7 requires development to respect character – amend to reflect this 
•	Policy EN2 is not explicit enough in protecting designated sites. Need a clear unambiguous commitment to recreation, restoration and enhancement of lost/damaged sites. Suggest use English Nature model policies (English Nature)
•	Add reference to the importance of farmland biodiversity in Policy EN2 as identified by Oxfordshire Wildlife Landscape Study (OWLS) 
•	Policy EN3 does not properly reflect PPG7, amend to refer to – development should be on lower grade land unless other sustainability considerations apply; not permitting loss of best and most versatile land unless other opportunities assessed first and if unavoidable use lower grade land first; delete requirement to overriding need
•	Not sure policy EN5 is necessary in the Structure Plan, would be better placed in Oxford Local Plan (GOSE)
•	Policy EN5 - Need commitment to protecting overall character of historic landscape of townscape and landscape, not only Oxford
•	Policy EN6 - Introduction of international significance for geological sites does not work and may be misleading (English Heritage)
•	Inclusion of geology is confusing – archaeology and geology concern different aspects of the environment and have different characteristics. Restructure EN6 to clarify, or delete geology
•	EN6 - Giving same level of protection to geological sites as archaeology unnecessary, not supported by Government advice, and are protected by Countryside and Wildlife Acts
•	EN7 and EN9 - Add reference that developers must consult with and act on advice of Environment Agency and the water company (Thames Water Utilities, Environment Agency)
•	EN8 - Amend to reflect that a Flood Risk Assessment will be needed for all development proposals in accordance with PPG25 
•	Policy EN10 - Add statement that any proposal should minimise adverse impacts and show landscape and wildlife benefits (CPRE Oxfordshire)

Chapter 6 – Developing the local economy

Comments on developing the local economy included the following:

•	Plan is not following RPG9 in promoting and encouraging economic success throughout the county
•	Plan is not promoting a balance of employment types to maintain a diverse economy in line with RPG9 e.g. precluding the location of footloose industry/warehousing/distribution 
•	Other towns should be considered for new employment development, including: Thame, Wallingford, Wantage, Chipping Norton, Grove, Carterton, Abingdon, Faringdon, Kidlington
•	Support for the restriction of warehousing/distribution centres as these employ relatively few people
•	Support for policy that encourages small scale employment opportunities, particularly in rural areas and those involving agricultural diversification
•	Greater emphasis should be given to mixed use schemes to help address imbalances in jobs/workforce and high levels of commuting, as in line with government guidance in PPG3 and 13
•	The role of Banbury and Bicester should be recognised in so far as both have a role to play in attracting and catering for the expanding science and knowledge based industries of the county 
•	Consideration should be given to a separate policy on strategic sites for different clusters/sectors (SEERA)

Policy E1:

•	Restraint policy in Oxford will damage the economy of the City and the county as a whole in the long term. Oxford could lose attractive businesses to other locations around the county or region
•	Policy of restraint is now no longer appropriate, particularly as there have been changes in circumstance since the last Structure Plan was adopted e.g. allocation of houses south of Grenoble Road, change of development strategy, Oxford’s status as a regional transport hub, its focus for knowledge based industry, objectives of RPG9
•	Concern over the adverse impact on the economy and the potential shortfall in employment land supply. Will damage the local economy and encourage unsustainable commuting patterns
•	E1 is too restrictive, should provide for exceptions where existing employment generating uses need to expand in their present location, but where such land is not already used or allocated for such purposes 
•	Policy may undermine the economic stability of Oxford City. Imbalance of jobs/workforce is not sufficient justification for restraining land for employment uses. Housing in the Country Towns has not been matched by employment. Plan should take a positive approach by promoting more employment provision in the Country Towns, Oxford and other locations 
•	The Structure Plan should incorporate a clear strategy for maintaining and accommodating the growth of businesses for which a location in Oxford is locational requirement e.g. expansion of university facilities 
•	A blanket restraint on Oxford without appropriate criteria is harmful to key employment sectors. Presumption in favour of loss of employment land is not supported, this is a Local Plan issue based on a range of factors. E1 is imprecise and will lead to interpretation and implementation problems (Oxford City Council)
•	Do not believe that Oxford’s employment needs can continue to be accommodated on existing or allocated sites in the longer term as the quality and range of sites do not obviously exist. Policy needs to be re-examined to ensure that Oxford and its immediate surrounds has suitable quality sites for business in the leading economic sectors as the Plan period unfolds 
•	Policy will compromise the City’s ability to sustain and regenerate its economy. May invite the closure of businesses given that land for housing has a higher value than employment. Only justified if new sites could be made available for employment to compensate any losses 

Policy E2:

•	Fails to acknowledge that there are large education sector/employment sites such as Wheatley Campus where further employment generating development would be consistent with the County Council’s economic strategy (Oxford Brookes University)
•	Inconsistency between the economic strategy and policies. Policies fail to acknowledge that outside Oxford, Oxfordshire’s existing/emerging clusters such as the Culham Science Centre are in the main located away from the main towns (UKAEA)
•	There is a need to take into account proposals in the Regional Economic Strategy and in particular provide sites for growing businesses and inward investors (SEERA)

Policy E3:

•	Does not explicitly permit the conversion of existing rural buildings for employment generating use as in the Structure Plan 2011 (Policy E6) (Oxfordshire Rural Community Council)
•	Present Structure Plan policy E4 and the supporting text has often been interpreted that such development can only take place when the scheme as a whole relates to not more than 500 metres, proposed policy is open to the same misinterpretation 
•	Expect this chapter to state unequivocally the case for improving the rural economy. Only passing reference made to farming, the rural economy and employment in rural areas. Reconsider the restrictions that it is likely to impose on rural businesses and the rural economy as a whole (Country Land & Business Association)

Policy E4:

•	Does not contain policy towards the planning and development of visitor accommodation (SEERA)
•	A better defined policy framework is required to ensure that the best possible use of the county’s tourist assets are utilised and safeguarded 

Policy E5:

•	Policy may impose an unreasonable and unnecessary constraint on employment generating development to the detriment of the Oxfordshire economy 
•	Policy tackles the question of balance from the wrong perspective. Employment growth should be encouraged in those locations where it is likely to thrive and succeed and housing should then be then directed to those locations to provide support for growth
•	Phrase “account will be taken of” is vague and open to misinterpretation. Possible that E5 requirement will be deployed to restrict or delay legitimate employment development in conflict with the objective of promoting employment development at the main towns 

Chapter 7 – Housing

The vast majority of comments on this chapter concerned policy H1 and the proposed urban extension to Oxford, south of Grenoble Road.

Policy H1:

Objections to development south of Grenoble Road:

Approximately 1,900 objections to development south of Grenoble Road were received during the consultation period.

(a)	Standard Objections:

Three campaigns encouraged standard objections to be submitted. The key points from these are summarised below:

1.	South Oxfordshire District Council campaign objection (320 responses)

•	Would erode the Green Belt, set a harmful precedent, lead to coalescence, the area is physically isolated, there are overriding physical constraints in the area, development would result in excessive congestion and considerable amounts of traffic
•	The objectives of the Green Belt remain valid and the County Council’s proposals would be in direct conflict with them. Exceptional circumstances have not been set out as required by the Government’s PPG2 on Green Belts. The County Council’s own Working Group recommended development outside the Green Belt at Bicester. The approach to meeting the county's housing requirements will lead to villages being swallowed up. This is not a sustainable approach to planning as called for by the Government. Would be difficult to integrate the new community with the main part of the city and provide access to local services. Moving the physical constraints will considerably reduce the value of the development, making it difficult to achieve affordable housing and other contributions
•	The County Council has not taken a sensible approach to meeting the county's housing needs and is urged to rescind its decision and recommend development at Bicester, not in the Green Belt. Delete reference to housing in the Green Belt south of Grenoble Road, Oxford

2.	Oxford Preservation Trust campaign objection (438 responses)

•	Object to the proposed Green Belt release south of Grenoble Road highlighted in H1 and paragraph 3.9. Will undermine whole concept of a buffer around the city and will set a precedent
•	Delete all references to Grenoble Road development in H1 and paragraph 3.9

3.	Sunningwell Parishioners Against Damage to the Environment (SPADE) campaign objection (352 responses)

•	Green Belt encroachment should only be considered if all other possibilities have been exhausted. Will encourage other proposals for inappropriate development
•	A more rigorous examination should be made of other options before adopting the proposal south of Grenoble Road, should strive to meet Government guidelines of 60% of development on previously developed land

(b)	Other Objections:

Approximately 886 other objections were received from organisations and members of the public to proposed development south of Grenoble Road. Objections were made on the following grounds:

•	Would set a precedent for further development in the Green Belt
•	Cause coalescence of Oxford with surrounding settlements
•	Damage the landscape of Oxfordshire and the historic setting of Oxford
•	Damage an important recreational amenity/open space around the city
•	Lead to increased urban sprawl
•	Have potential traffic/transport implications
•	Impact on existing services, facilities and infrastructure
•	The area would be isolated from the rest of the city, no sense of community
•	No exceptional circumstances for development in the Green Belt have been identified in line with PPG2
•	A full review of the Green Belt should have been carried out
•	The allocation south of Grenoble Road appears to have been made at the last minute
•	More suitable alternatives must exist elsewhere in the county for this amount of houses e.g. brownfield land, spread in small amounts of development in villages, continue development in growth areas or revert to development at Bicester
•	The site will not be financially viable in terms of being able to provide needed affordable housing and overcome constraints such as the sewage works and electricity pylons 
•	The proposal is contrary to other policies in the Plan e.g. G4 and EN5

Representations in support of development south of Grenoble Road

•	Support development south of Grenoble Road which would support the strategic aim of locating housing close to Oxford, employment and public transport links
•	Urban extension to Oxford is the most sustainable option for provision of housing, site could provide 3,500 dwellings. Grove is unsustainable in terms of jobs, services and transport 
•	Support urban extension to Oxford with modifications. If not supported will have serious consequences, including serious housing problems. No justification for limiting to 1000 dwellings. Costs of constraints are reason for a larger proposal. Plan the whole area in sustainable/comprehensive manner. Could base on Green Belt swap idea.  Amend "about 1000" to "about 2500 dwellings as part of comprehensively planned urban extension of about 4000-5000 dwellings" (Oxford City Council)

Other representations concerning Policy H1

•	Support proposals for 4,500 houses at Didcot. Should be no growth above this as the town needs time to absorb high levels of growth and provide facilities, no further capacity due to existing transport issues on local roads and little prospect of A34 improvements (South Oxfordshire DC and others)
•	The country towns are constrained or have major development planned at them, should consider proposals for freestanding or expanded settlements on previously developed land
•	Figure of 2,700 for Witney is likely to be exceeded. Sensible to increase Witney figure and decrease the figure for the remainder rural area (West Oxfordshire DC)
•	No further development should be located in Witney or surrounding area until the required/necessary road and other infrastructure/services are constructed 
•	Grove is not consistent with putting housing where jobs are and the need to reduce travel, also has issues regarding flooding, not a sustainable location
•	Need a realistic approach to affordable housing provision by increasing the overall supply and to counter the shortfall of dwellings in the south east and the low rate of completions in Oxfordshire. This will impact on the prosperity of the county. Figures for the districts should be seen as minima 
•	A separate policy is needed to advice on actions to address low build rates
•	Previously developed land target should be 60% in line with RPG9 requirements
•	Previously developed land target is not practical considering the context of Oxfordshire,  districts are likely to have different characteristics
•	Object to further development at Bicester – facilities and infrastructure are already insufficient
•	Housing numbers for Bicester and Banbury have fallen reflecting capacity concerns and the need for services and facilities to catch up (Cherwell DC)
•	Bicester is still a sustainable location for development as demonstrated and supported by the County Council Working Group and Officers recommendation
•	No reference is included to the special needs of Faringdon and that the town needs additional housing to survive
•	Concerns about linkages between proposed housing at Bicester, Didcot and Grove and the assumption that there will be major improvements to the A34 by 2016 (Highways Agency)
•	Object to possible development at Berinsfield. Exceptional circumstances may be to give better social balance, but similar arguments could justify more affordable housing in other villages as part of larger full market schemes
•	Development of a new ‘Penbridge’ community should be considered now in a location with excellent connections to major traffic corridors, opportunities for employment generating uses, potential ‘zero environmental impacts’ and landscape enhancement
•	Important that smaller towns and villages have sufficient development to encourage the use of services and facilities
•	Policy H1 should be amended to add reference to Shipton on Cherwell Quarry (about 2,500 dwellings of which 1,500 should be in the Plan period) 

Policy H2:

•	Approximately 117 supporting representations to Policy H2 were received for the following reasons: transport problems would occur with more development; amount of development is suitable for a sustainable community in a rural location and will enable environmental improvements on the site; the amount of dwellings on the site has been agreed after many years of consultation; policy reflects the decision of the Secretary of State and the views of Cherwell District Council (including - Cherwell DC, 9 Town and Parish Councils, Cherwell Valley Parishes, South Northants DC, Network Rail Infrastructure Ltd, CPRE)
•	Upper Heyford was major new town when used by US Services, should be a new town of 15-20,000 people, should not waste a large brownfield site
•	Increase to 3000 dwellings to reduce need for development at Didcot/edge of Oxford 
•	5000 dwelling settlement could justify new station at Ardley, brownfield site is ideal. 1000 dwellings would be isolated with minimal services (Rail Future)
•	Upper Heyford is not sustainable in terms of transport and PPG3. It is isolated, lacks facilities, fails to meet wider needs of Oxon, and should be reconsidered. Other locations are more sustainable e.g. – Bicester, safeguarded and previously developed sites on edge of Oxford, Banbury 
•	Reference to “maximum of about 1000 dwellings” in policy and modest development in text is inconsistent (Cherwell DC)
•	Concern that no strategic housing development has come forward, query if prescriptive site specific policy is still appropriate in the Structure Plan (GOSE)
•	Refer to the opportunity to provide affordable housing on the site 
•	Policy must include reference to the Cold War heritage potential of the Upper Heyford site in order to avoid conflict with other policies in the Plan (Oxford Trust for Contemporary History)

Policy H3:
	
•	Not a Structure Plan matter to require specific densities, particularly if more than Government advice. 50 dwellings per hectare may not be appropriate in historic town centres. Is a matter for District Councils to determine (South Oxfordshire DC)
•	Could lead to inappropriate development in villages and erode character. Amend to steer higher densities to urban areas, and not at the expense of character of the environment (West Oxfordshire DC)
•	50 dwellings per hectare may not be appropriate in rural areas 
•	50 dwelling per hectare will create future problem areas. 30-40 supported in urban areas, proposed density would compromise well being of future residents – 20-25 should be the limit
•	Policy is contrary to PPG3, revise to promote development between 30-50 dwellings per hectare, with greater densities where there is high/good frequency public transport 
•	Density policy is unacceptably prescriptive, insert “normally”
•	Developers forced into high densities will not fund enough infrastructure and transport improvements 

Policy H4:

•	Priority given to affordable housing in the Plan is supported (SEERA, District Councils, Oxfordshire Rural Community Council and others)
•	General uncertainty of whether the target is achievable
•	The target is not justified or backed up by evidence
•	The policy is contrary to Government guidance in PPG12, PPG3 and Circular 6/98
•	Structure Plans should not set thresholds and impose targets on districts, they should act as a guide for districts. Level of affordable housing should be established by the Districts
•	Does not take into account economic viability
•	The amount of affordable housing should be determined on a site by site basis
•	Target is unrealistic given the need to provide other infrastructure
•	Could delay housing being brought forward generally and on previously developed land
•	Plan fails to provide details of how affordable housing will be monitored
•	The idea of seeking contributions from commercial development for affordable housing is attractive. Incorporate into the policy to give more weight (Vale of White Horse DC)
•	Highlighting the scale of affordable need in Oxfordshire will help the districts achieve affordable housing targets
•	Target is too low and should be increased considering the need in Oxfordshire
•	Greenfield land will need to be released to achieve 50% target
•	Affordable housing should be built in small settlements in rural areas where there is a high need
•	The County Council will need to provide robust and up to date evidence to the EIP to justify the stance and policy (GOSE)
•	Support policy but important that all District Councils make effort towards increasing affordable and key worker housing provision to avoid pressure on Oxford. Local Planning Authorities should decide need breakdown based on local assessments rather the Structure Plan treating as one group (Oxford City Council)

Chapter 8 – Town Centres

Comments made on this chapter were made generally on specific changes to text and policies and firming up of phrases e.g. define ‘what major new development’ actually means.

•	Comments that other locations could see some additional development in their centre and be included in the list of main locations, these included: Thame, Kidlington, Wallingford, Brightwell-cum-Sotwell, Carterton, Abingdon and Chipping Norton
•	Consideration of out of centre sites should be ruled out on sustainability grounds
•	No reference to market towns in the Plan. They have the ability to act as hubs for the surrounding rural areas and the viability of market towns is imperative for the economic, social and environmental sustainability of the area (Country Land & Business Association)
•	Town centres have an important role to play in meeting housing needs, surprise that there is no link between housing provision and town centre policies, should be intrinsically linked to housing policies (A Consortium of Housing Associations)
•	Policy TC1 needs to recognise the importance of satellite ‘economic’ centres within Oxford (Summertown, Temple Cowley, Cowley Road etc). These maintain the viability of the different communities and can be equally harmed by over development within Oxford (Oxford City Council, Oxfordshire Green Party)
•	Bicester town centre has no space to accommodate new development, out of centre development is the only option 

Chapter 9 – Recreation and Leisure

Generally there was support for policies and the chapter as a whole with a number of comments on specific issues.

•	Support for the protection given to the River Thames.
•	There should be a specific policy relating to the protection of other important waterways e.g. Oxford canal and route of the Wilts and Berks Canal (Wilts and Berks Canal Trust)
•	Some comments were made on the need to make reference to special issues e.g. greater protection to the Ridgeway
•	Concern that there is no specific policy for recreation and leisure as a whole rather than just focusing on countryside recreation.
•	Concerns over restricting permanent moorings on the River Thames, they can enhance character and provide needed affordable housing (ACTVaR, Environment Agency, Green Party)
•	A lack of adequate public transport systems means that the use of existing countryside recreational facilities and resources will continue to be limited to those using car transport 

Chapter 10 - Energy 

A number of changes were suggested to policies. Most comments however relate to the text.
 
•	Suggest rewrite EG1 to deal more directly with climate change mitigation and adaptation (National Trust)
•	Policy EG1 presumes the greatest potential for renewable energy is from biomass. It should be more generic and encourage exploitation of other potential resources, including wind, active and passive solar, water (Oxfordshire Green Party, Oxford City Council)
•	There is a lack of a specific policy or text encouraging development of wind turbines or referring to them in addition to biomass 
•	Support for encouraging energy efficient design, including renewables 
•	Combined Heat and Power (CHP) should be incorporated in major new development. Waste heat from Didcot Power Stations should be used

Chapter 11 - Minerals

The great majority of representations to this chapter concerned Policy M2
  
•	There was some support, particularly from the minerals industry, for the inclusion of strategic areas for sand and gravel working in the Structure Plan.

Policy M1:

•	There was general support for policy M1. Some respondents raised concerns about the impact of further mineral working in Oxfordshire, and suggested there should be more emphasis on protection of the historic environment, archaeology, landscape, villages and residential amenity.  Two respondents wished to see recreational afteruses added as a restoration objective

Policy M2:

A large number of objections have been made to the proposed new area for sand and gravel working in the Stadhampton-Berinsfield-Warborough-Benson (SBWB) area.  Of the total objections received to policy M2 approximately 160 were in the form of two standard objections letters. The main points from all the objections received are set out below:

•	Identification of an area of search in the Structure Plan is at variance with national planning guidance and is not an approach taken by other mineral planning authorities
•	The sub-regional aggregates apportionment figure for Oxfordshire on which the need for the SBWB area is based is too high; the actual need for aggregates is lower than this and therefore a lower figure should be used
•	The site assessment process used to select the SBWB area was inconsistent and not sufficiently detailed or robust
•	Preference should be given to extension of existing working areas, and there are other more suitable and less constrained areas located closer to the strategic road network (particularly the A34) and areas of major new development
•	The SBWB area is poorly located in relation to the major road network and main areas of new development, particularly Didcot and Grove
•	The local road network including the A4074 and A329 is not suitable for increased HGV traffic
•	Noise and dust from extraction, processing and traffic would adversely affect the tranquil rural character of local villages
•	The landscape of the SBWB area is very sensitive, being located adjacent to the Chiltern Hills and North Wessex Downs AONBs, and mostly being within the Green Belt and an Area of Great Landscape Value
•	Wet restoration would create a birdstrike risk within the safeguarding zone for RAF Benson 
•	The area is one of the richest archaeological sections of the Thames valley 
•	Mineral working and restoration would adversely affect important ecological habitats and the potential for habitat restoration
•	Would cause permanent loss of best and most versatile agricultural land
•	The proposed mineral working area would adversely affect local property values
•	The high water table in the area means workings would have to be pumped out, which would have local environmental impacts and surrounding water levels
•	Mineral working, plant and screening measures would be an intrusion in the flat, open, highly visible landscape of the area
•	Would sever footpaths and adversely affect tourism and the local economy 
•	A small number of objections have been made to the deletion of Sutton Wick and Sutton Courtenay as strategic areas for sand and gravel working in Policy M2
•	A small number of objections have also been made to the inclusion of Eynsham in the Eynsham-Cassington-Yarnton area, on the grounds that the Inspector who held the Inquiry into the Minerals and Waste Local Plan in 1995 concluded that land at Eynsham should not be identified in the Local Plan
•	Some industry objectors wish to see a more flexible approach to provision for future sand and gravel working, with Policy M2 allowing sites outside the strategic areas to be permitted or identified through the Minerals and Waste Local Plan
•	The following additional or alternative strategic areas for sand and gravel working have been proposed for inclusion in Policy M2 by minerals industry or landowner objectors and objectors to the SBWB area, including: Langford area, between Carterton and Lechlade; Lechlade – Clanfield; westward extension of the Lower Windrush Valley area towards Clanfield; northwest of Cassington; south of Yarnton; Wallingford – Cholsey; Caversham (north of Sonning Eye); Sutton Courtenay/Didcot; Radley; Marcham; Culham – Clifton Hampden; Appleford – Little Wittenham; Oakley Wood

Policies M3 and M4:

There were very few comments on Policies M3 and M4, but the policies were generally supported. 

Chapter 12 - Waste management

•	The waste management policies were generally supported
•	There were some objections to making provision for waste from London in Policy WM1
•	Two industry respondents wished to see a less restrictive approach to provision for waste from outside the county  
•	There was strong support for the encouragement given to increased recycling by Policy WM2
•	Two industry respondents wished to see Sutton Courtenay/Didcot identified as a strategic waste management location in Policy WM2, and another wished to see a less restrictive approach to the location of recycling plants  
•	One respondent wished to see more active encouragement of resource recovery through energy from waste
•	The statement in paragraph 12.15 about the location of waste management facilities in the Green Belt where special circumstances apply was supported by a few respondents, but others objected to this and wished to see a stronger statement of protection of the Green Belt 
•	One respondent was concerned that the restriction on landfilling in Policy WM3 will lead to under-provision in Oxfordshire and the export of waste to adjoining counties for disposal

Representations on Alternative Development Proposals:	

Objections to ‘Penbridge’ Sunningwell proposal

Approximately 390 representations were received objecting to a proposed new settlement near Sunningwell. The majority of these were standard objections, the key points from these and other objections are set out below:

(a)	Standard Objection:

Sunningwell Parishioners Against Damage to the Environment (SPADE) (352 responses)

•	Proposal is opportunistic, seeking respectability by the adoption of ‘eco’ credentials and the inclusion of limited affordable housing. Concerns regarding impacts on the Green Belt, congestion, over burden on road infrastructure and impacts on farmland biodiversity. 
•	Not consistent with PPG2 in terms of altering the Green Belt only in exceptional circumstances. All opportunities for development outside the Green Belt should be considered. Land for the Penbridge proposal is wholly within the Green Belt and would involve an extensive revision and lead to the urbanisation of a vast tract of land effectively linking Abingdon with the villages of Sunningwell and Bayworth.

(b)	Other Objections:

Other objections were received regarding the Penbridge proposal on the following grounds:

•	Development will occur in the Green Belt
•	Will result in loss of farmland
•	Development will damage landscape, wildlife and biodiversity of the rural area
•	Will set a precedent for further development in the Green Belt
•	Would increase pressure on the already overcrowded A34 and will cause additional traffic in general
•	No supporting infrastructure in the area to support additional houses
•	Would damage rural communities and villages and result in loss of identity/community
•	The proposal is contrary to Structure Plan and Government policy 
•	Priority should be to develop brownfield sites before greenfield areas
•	Area has important recreational amenity

Representations regarding Shipton-on-Cherwell Quarry

Twelve representations were received specifically commenting on development located at Shipton-on-Cherwell Quarry:

•	There was support for development because it would involve the redevelopment of a brownfield site
•	Concerns were expressed at the likely increase in traffic, particularly on local roads
•	Concern that development could damage an important wildlife area