Kirtlington Parish Council Response to Reg. 19 Consultation
Chapter 3: Strategy for Development in Cherwell
Kirtlington Parish Council (KPC) supports the Cherwell District Council (CDC) Spatial Strategy for Rural Areas to “protect the identity and character of villages and rural areas and avoid unplanned development in the open countryside” (page 22). We also agree the CDC’s strategy to “focus new development on Bicester, Banbury and to a lesser extent Kidlington” (page 20).
However, it should be noted that the encroachment of towns on to green field sites and towards villages can adversely affect villages and rural landscapes. We are not convinced, that this Local Plan recognises sufficiently the impact of the sites for proposed developments on the rural landscape in the District and on the villages within it like Kirtlington. We are also not convinced that the Local Plan sufficiently considers the ability of roads like the A4095 through Kirtlington to cope with the additional traffic that will be generated, and it does not assess the impact of its proposed policies on villages like Kirtlington through which the additional traffic will pass. (e.g. POLICY KID H1 on the A4095 Southeast of Woodstock).
Policy SP 1 The Categorisation of Settlements within the Settlement Hierarchy
KPC agrees with the categorisation of Kirtlington as a Category B Village, not least in light of the loss of our shop, our post office and the closure of the Dashwood Arms (a café, pub and hotel). However, we would claim that we do not have “good transport links to villages and towns with a good range of services and facilities” (page 25, description for Category B Villages). Although Kirtlington has, quite properly, been downgraded to Category B in this Reg 19 version of the Local Plan, from its previous Category A ranking in the 2015 Local Plan, it could even be argued that it should be Category C, based on the current level of facilities in the village.
CDC’s Settlement Hierarchy Topic Paper, dated December 2024, underpins its settlement hierarchy for the Local Plan Review. It is therefore particularly disappointing to find that it contains much information that is out of date and/or inaccurate. There appear to be several errors including basic arithmetical ones. Taken together, these are likely to lead to challenges from any villages affected adversely.
We do not dispute the overall outcome for our own village as the lost amenities alone over recent years mean that Kirtlington cannot now be considered a sustainable village, regardless of its size. Nevertheless, there are errors in the Topic Paper for Kirtlington. For example, Kirtlington, is referred to as having good connectivity with Heyford Park by bus, yet that service was withdrawn in 2023. There are far too many small errors to itemise them all. One example is where Kirtlington is, quite properly, awarded a point for its allotments, but in the neighbouring entry, no point is awarded for Bletchingdon’s allotments. Several more such small inaccuracies pepper the system of awarding points to villages. These errors will inevitably undermine confidence in the soundness of CDC’s overall assessments to provide an accurate evaluation of villages’ sustainability.
KPC recognises the benefits that can be gained from permitted housing development within Kirtlington to help with the viability and the vitality of the village and to address any known local housing needs. However, the size of any future development in Kirtlington has to be commensurate with its current sustainability credentials, in line with its Category B ranking. We would also expect any such small development to deliver as many benefits as possible; e.g., a greater number of affordable homes than dictated by policy, funding towards our bus service and improvements to our inadequate sewerage system.
Policy CSD 15 Green and Blue Infrastructure
KPC supports this policy and will rigorously pursue genuine on-site biodiversity net gain in any future developments in our Parish. If direct on-site provision is not possible for any reason, we would require off-site provision to be within the Parish.
Policy COM 11 – Cherwell Local Landscape Designations
KPC welcomes the reinstatement of Areas of High Landscape Value as previously included in the 1996 Local Plan, and now rebadged as Local Landscape Designations. This designation rightly recognises that the landscape of the Cherwell Valley to the west of Kirtlington is a valued landscape in terms of Paragraph 187a) of the NPPF (Dec 2024).
However, the poor quality of the overall Policies Map is disappointing. It is the only map showing rural areas (if they are not included on the detailed plans for potential site allocations) and it is at such a low resolution that it is illegible. The map also does not include the potential settlement gaps, making it very difficult to gauge the overlap with LLDs and other designations.
Policy COM 13 Settlement Gaps
KPC supports the policy of establishing settlement gaps to “maintain the separate identity of settlements and prevent coalescence of built-up areas”. The provision of area maps is welcome and a set of criteria backed up by the evidence in the Green Gaps Study means that this policy should help accurately identify the areas where gaps are needed.
The Local Plan does not apply its gap policy consistently across the district. We note that the Plan refers to settlement gaps, green gaps and strategic gaps but only Strategic Gap is defined in the Appendix 10 Glossary. Strategic gaps should protect the character and setting of our rural villages by conserving the openness that countryside provides for settlement separation. Policies should also ensure that growth is well managed and sustainable, in alignment with the NPPF principles of landscape characterisation and sustainable development as outlined in the NPPF.
The gap policy in the Local Plan has only been applied in relation to the three main settlements of Bicester, Banbury and Heyford Park. Preserving gaps between villages is at least as important, but no gaps are proposed for this. Should this policy not be integrated with COM 10 and COM 12? Also, the maps in Appendix 4 show that some gaps between the main settlements and their surrounding villages are already too limited to provide a sense of leaving one settlement before entering another.
Setting criteria against which to measure the performance of a gap, in maintaining the physical and visual separation between identified settlements, is critical. These criteria should consider issues such as distance (e.g., a minimum width for gaps, such as one mile or 1,500 metres), land uses, visual intervisibility, particularly where the topography affords long distance views across a gap’s landform and other thresholds that are required to preserve the separate identity of villages.
At present, COM 10 provides Kirtlington with some limited landscape protection, but a designated gap would demonstrate the importance of the open countryside between Kirtlington and Bletchingdon. The recent large development at Bletchingdon has already expanded the village very considerably northwards towards, and in full view of, Kirtlington. The distance between the northern edge of Bletchingdon and the southern edge of Kirtlington is already less than a mile. Both villages occupy highly visible hilltop positions and each is already in view of the other. We would argue that, at the least, there needs to be an additional formal gap here to stop further spread northwards.
Policy RUR 1: Rural Areas Housing Strategy
Mid Cherwell Neighbourhood Plan housing allocation
CDC is proposing 100 housing units to the Mid Cherwell Neighbourhood Plan area. These are to be allocated between the MCNP’s villages, including Kirtlington. We do not know how this figure of 100 units was reached or justified, but it is a very considerable increase in the number allocated (36) in the current Neighbourhood Plan to 2030.
We are not convinced that the proposed number of 100 is realistic. This is not least because in CDC’s Housing and Economic Land Availability Assessment, (HELAA) of November 2024, only 9 sites across the whole MCNP area are deemed ‘suitable’ for housing. We understand that the MCNP has identified potential sites to accommodate 71 housing units across the MCNP’s Category A, B and C villages, but has been unable to identify suitable sites for the remainder. We accept that, as a proposed Category B village, Kirtlington is being promoted by the MCNP as one of its villages to contribute to the overall MCNP total. However, what is CDC’s expectation of the MCNP’s villages, including Kirtlington, if suitable sites cannot be identified to match CDC’s expectation of 100?
Additional complications for Kirtlington are that CDC has determined that all of the sites for Kirtlington in the HELAA are ‘unsuitable’ (even for a Category A village). These include the site most strongly supported by our community. To contribute to the MCNP’s allocation, Kirtlington would therefore be obliged to put forward for consideration the site favoured by our community that we consider to be the least unsuitable of the sites judged to be ‘unsuitable’ in the HELAA. However, we understand that CDC has also advised that sites not in the HELAA can be considered, which opens the possibility of putting forward a site that has not been assessed in the HELAA.
Policy RUR 1 Rural Areas Housing Strategy
RUR H1 Land West of Springwell Hill, Bletchingdon
KPC does not support the inclusion of proposed Policy RUR H1 (Land west of Springwell Hill) in the Local Plan. Policy RUR H1 allocates a site for further expansion (for at least 44 more units) beyond the large-scale recent enlargement of Bletchingdon beyond its former settlement boundary that is already spreading northwards down the hillside towards Kirtlington. This proposal is a concern for Kirtlington and KPC has been made aware of concerns among the residents of Bletchingdon.
Regarding the soundness of the proposed policy RUR H1, we point out that there has been no prior consultation with KPC or Kirtlington’s residents about this policy despite the obvious implications for our village. Also, there is no natural field, or other boundary along the northern edge of the proposed allocation of RUR H1. The line drawn is only ‘indicative’, which is strongly suggestive of an intention to encroach even further down into the valley. Access to the site is not viable on to the blind bend on the narrow minor road of Springwell Hill; it would have to be via the existing development.
Also, this site has clearly been identified for further major development as it is located just outside the northern border of Oxford’s Green Belt. This is particularly relevant for Kirtlington as Bletchingdon has already recently been developed enormously and disproportionately beyond its original settlement boundary to the north. Any further northern extension would be an additional suburban enclave divided from the rest of the village, with a different character from the village and an entirely separate identity. Building a large development just outside the northern edge of the Green Belt in this location at Springwell Hill runs counter to the intention of the Green Belt to safeguard the countryside from encroachment.
We argue that Policy RUR H1 should not be implemented as part of the Local Plan to prevent further expansion spilling down into the valley that separates our two villages. The visual openness here increases the impact and any additional housing would be highly visible within that open landscape, not only from Kirtlington itself, but from sections of the Bletchingdon Road and across the whole valley from the A4095 at Lince Lane. It is important that the remaining openness is not further reduced. An additional gap should be designated to retain the open views between Kirtlington and Bletchingdon because views between the two villages are of importance to the perceived character and rurality of the area.
Notwithstanding KPC’s in principle objection to any further development at all on this site at Springwell Hill, if this site allocation were to come forward, we would request that the key design requirements are strengthened as follows:
Item 4: Infrastructure requirements should include the provision of a footpath between Kirtlington and Bletchingdon.
Item 6: In addition to pulling back developable areas from the eastern and northern boundaries, it should be specified that these edges of the expanded settlement are planted with woodland, commensurate in depth to the existing woodland along Springwell Hill (thus over 20m wide).
Item 10: We can confirm, through our intimate knowledge of this road, that a satisfactory design for the proposed access off Springwell Hill cannot be achieved within the constraints of the land in the proposed allocation. Moving the access further to the north would further segregate this development from the rest of Bletchingdon and extend the settlement form even closer to Kirtlington. Access through the existing Duchy development would have to be the only option included in this item.
More generally, we believe that allocating sites within the Green Belt must now be considered, not least in light of the already considerable expansion in recent years of Category A villages in the District outside the Green Belt.
It is not part of the Green Belt’s purpose to encourage the proliferation of developments just outside it and around its edges. Rather, from the outset, the rural landscapes and villages beyond the outer limits of the Green Belt were considered to be far enough away from the town centres not to need Green Belt protection from unsuitable development. Experience has clearly proved this not to be the case.
TRAFFIC AND TRANSPORT
Policy CSD 22: Sustainable Transport and Connectivity Improvements
“Encouraging sustainable transport modes, low-carbon technologies, and living close to jobs, education, services and amenities can lead to reduced travel, reduced carbon emissions and generally more sustainable communities” (Paragraph 3.127).
The National Planning Policy Framework (NPPF) (Para 109) specifies that changes to the transport infrastructure, required as a result of new developments, specifically including safety issues and infrastructure deficiencies, should be addressed. This includes an appropriate mix of transport methods rather than over-reliance on the private car, collecting data on traffic and pollution, more frequent bus services (relevant also to avoiding social exclusion) and actions to facilitate health, recreation and wellbeing.
KPC is pleased to note that the CD Local Plan 2042 recognises the need for sustainable transport modes which are benign to the environment, recognises the requirement to improve the transport infrastructure, and encourages ‘active travel’ and the use of public transport (as stated in Policy CSD 22). However, KPC and its Traffic Calming Sub-Committee on behalf of Kirtlington’s residents are disappointed to note that there are no specific traffic and transport plans for rural areas mentioned in the Local Plan to offset the effects of the proposed further developments for housing and employment which will surround Kirtlington and have a potentially profound effect on roads through our village, especially the A4095.
Kirtlington has a particular concern as the A4095 runs right through the centre of the village and its Conservation Area. The road is narrow in places, including directly in front of the primary school, and the peak morning and afternoon traffic coincides with the start and finish of the school day. Two ‘near misses’ involving children were recorded here in 2024 and vehicles frequently mount the village pavements where the road is narrow. Traffic calming measures, including the recent 20mph speed limit and ‘place making’ (large wooden planters, etc.) have been largely ineffective in reducing the speed of the traffic. Heavy goods vehicles (HGVs) are a particular concern.
Whereas it might be hoped that the proposed developments in Banbury, Bicester, Kidlington and around Woodstock would be occupied by those living and working locally, that is far from certain. Resultant additional traffic may principally be travelling to and from Oxford or accessing the M40, using the major transport arteries (such as the A34, A40, A41, A44 or A423). However, that is far from true of all. When commuting, many drivers choose to leave these main roads and cut through villages, including Kirtlington, to avoid congestion on major routes. Also, the frequent incidents on the A34, the lack of a direct connection between the A40 and A34 at Oxford, and other traffic issues cause traffic to divert on to the minor roads through Bletchingdon and Kirtlington or on to the A4095. This includes traffic seeking access to/from Junction 10 of the M40, sometimes to avoid Junction 9.
KPC would like to see come to fruition the commitments to work more closely with Oxford County Council (OCC) through its Local Transport and Connectivity Plan as included in Policy CSD 22 of the LP. This should include sharing the outcomes of analyses of trends in traffic data and projected anticipated traffic flows that would result from each of the proposed developments that potentially might generate traffic both through Kirtlington and at the already congested junctions in the area, including the Enslow Junction of the A4095 and the Springwell Hill/B4027junction at Bletchingdon.
KPC requires reassurances that the cumulative traffic effects of existing and committed developments (particularly at Heyford Park and at Great Wolf at Bicester Golf Course), and potential projects (e.g., the Strategic Rail Freight Interchange at Ardley, the Puy du Fou theme park and other proposed causes of employment and other traffic around Junctions 9 and 10 of the M40) have all been fully considered. Also, KPC needs to be involved in the consultations for any plans to restrict traffic over the Rousham bridge as these are relevant to the traffic flows in Kirtlington. CDC needs to demonstrate that it is putting pressure on Highways England to carry out much needed improvements to Junctions 9 and 10 of the M40, and that the land for these projects (such as grade separation) is safeguarded against development, rather than subsumed within allocations for employment uses.
The Local Plan refers to Cherwell’s good strategic local and public transport connections and yet CSD 22, 3.128 explains that in Oxfordshire traffic and transport is the largest contributor to carbon emissions “with 46% originating from road transport tailpipe emissions”. Linking these statements, we ask how CDC plans to improve the carbon emissions situation. We note that the Local Plan documents CDC’s concern that “traffic congestion is a major cost to the local economy and has the potential to constrain future growth” and goes on to be concerned about the overreliance on private cars. We ask how CDC plans to improve the situation.
We note that support for OCC’s Local Transport and Connectivity Plan 2022-2050 is referred to in the Local Plan. However, we are not clear about the current or future relationship between the District and the County with regard to the traffic and transport topics mentioned in the Plan “to ensure that transport improvements contribute positively to the attractiveness and safety of our quality of life in Cherwell”. Accordingly, KPC believes that the following actions are required to encourage safer traffic flows through Kirtlington and to encourage other forms of transportation:
• On Traffic Calming: Review of Traffic Calming measures in Kirtlington, especially adjacent to the primary school (initial meeting with OCC scheduled for 10 March 2025) and implementation of recommendations to reduce traffic speeds;
• On Air Quality: Air quality monitoring on the A4095, for example, in front of the primary school (in line with Policy CSD 16 and in light of the carbon emissions in the County from road transport tailpipe emissions);
• On Bus Services: The Local Plan highlights recent and future rail links, but this needs to be accompanied by more efficient and frequent public transport options from Kirtlington to the rail stations without use of a car. A review is needed of rural bus services through Kirtlington (current weekday frequency of bus #24 to Oxford and Bicester averages 2 hours,15 minutes, with current funding only confirmed annually).
Review to consider: (1) greater frequency, (2) access to commuter train services to London (via Oxford Parkway or Bicester North or Bicester Village stations) or to Banbury/Birmingham (via Bicester North station) and (3) access to doctors’ surgeries (Kirtlington is served by two doctors’ surgeries, one in Islip, the other in Woodstock, neither currently accessible by bus). Private car use will continue to increase unless there is efficiently timed linkage between bus routes serving different directions throughout the region.
• On Safe Roads: SCRIM tests (for skid resistance) conducted in the village and each approach. In particular. we believe this is needed for the Bletchingdon Road/Springwell Hill and for the Islip Road to the A34; these are used as our main connections to Oxford and to the A34 and are beyond end-of-life and a safety hazard due to wear, potholes and associated breaking up of the road surface (exacerbated by surface water runoff).
The Local Plan states “Living close to jobs, education, services and amenities can lead to reduced travel, reduced carbon emissions and generally more sustainable communities” and aims “to manage travel demand by reducing the need to travel, planning for sustainable travel modes and providing for zero emission vehicle use”. KPC asks what tangible measures CDC is proposing to meet the Plan’s climate change objectives, which include such ambiguous terms as “new rural modes of transport” (4th bullet on page 15) and how does CDC intend to decarbonise transport? Is there a commitment to install electric car charging points in villages (as has been promoted by villages themselves)?
In summary, on traffic and transport matters, CDC’s Local Plan identifies many potentially beneficial improvements, for connectivity for those in rural areas, enabling reduction of private car use, improved air quality and better sustainability, but what is less clear is the role that CDC will play in how these are to be achieved.