Please find Brightwell cum Sotwell Parish Council’s comments regarding the Joint Local Plan Preferred Options Paper (JLP).

In principle, Brightwell cum Sotwell Parish Council (BCS) supports the aspirations of the plan and where no comment is made, it should be assumed that BCS is in general agreement with the preferred option.

There are however, some specific options that our community has deep concern about – particularly Policies SP1 and SP2. These would have a significant negative impact on Brightwell cum Sotwell and as such we would strongly urge SODC to consider our concerns as set out in this paper. In addition, Brightwell cum Sotwell Parish Council would question the evidence base that supports this policy (as regards Brightwell cum Sotwell) as set out in The Settlement Assessment and Hierarchy Topic Paper.

Other comments made by BCS are intended to strengthen and support the core objectives of the Joint Local Plan and subsequent policy proposals.

BCS supports the key themes and objectives of the plan particularly measures to protect and enhance local heritage, protect local countryside, strengthen and build resilience to climate change, help nature recover, achieve high quality green space and promote healthy and active lifestyles.

SP1 and SP2 Spatial Strategy and Settlement Hierarchy

BCS strongly objects to the settlement hierarchy proposed in Policy SP2 that is supported by Policy SP1. Under this policy, Brightwell cum Sotwell is re-allocated as a Tier Three settlement whereas it has always been considered as a smaller village. In addition, BCS would challenge the assumptions made in the Settlement Assessment and Hierarchy Topic Paper (that underpins designation in the preferred options paper) for Brightwell cum Sotwell as a Tier Three settlement. We simply cannot understand how these have been made and why a decision to relocate the village’s hierarchy has got to this stage.

The Settlement Assessment and Hierarchy Topic Paper sets out the criteria for deciding the settlement hierarchy. These are based on a series of settlement assessment scores that take into account; services and infrastructure, proximity to Oxford, Swindon or Reading and connectivity. Brightwell cum Sotwell achieves a total score of 64, broken down as follows:

Facilities – 54 Proximity – 0 Connectivity – 10

Jason Debney Brightwell cum Sotwell Parish Council Stewart Village Hall West End Brightwell cum Sotwell 07761169343

The high score of 10 for connectivity is based solely upon the single bus service in that it provides a half hourly service through the village. This however has not always been the case. The service has regularly changed – some years providing only an hourly service (at best). The high level of service is based not on the needs of the village rather on where the Wallingford to Didcot service runs to and from (and where the buses are based or terminate!) and as such is vulnerable to changes in service provision.

The village fought hard to retain an hourly service as it does provide a lifeline for some villagers. Without this service they would be cut off from the outside world. This said, the vast majority of villagers do not use the service. The only viable bus route is to the north of the village and due to this location, places ALL the bus stops on the periphery of the settlement (and an uphill walk!) to the north of the main settlement. Many elderly people and those with disabilities simply do not regard the service as an option due to the distance that would be needed to be walked (with shopping for example) to access the bus stops. Re- routing the service through the centre of the main village has been considered however, buses are simply too big for the winding narrow lanes. A simple analysis of the use of the bus service by villagers would support this point – the bus being a lifeline for those who live to the north of the village and / or are able to walk to the bus stops but for many villagers it is not an option. Once at destination, the bus service often does not facilitate ease of use to achieve the goal of the trip being made in the first place. The service does not go to where many villagers need to go – it does not stop at the doctor’s surgery in Wallingford for example. Car use in this case being the only option.

BCS considers that the weighting of a score of 10 for the Brightwell cum Sotwell bus service cannot be justified. Without any analysis, all that is achieved is a tick box exercise that fails to respond to the real world. The service does not provide for all villagers (see above) and is simply not used by parishioners living in Sires Hill, Mackney or Shillingford Hill. Indeed, for the latter community, the parish has provided a locally funded service to meet their needs (when their service was cancelled) whilst we can raise the funds to support this.

To conclude, the location of the bus route does not make the service viable for all villagers and there is no guarantee that the level of service will not change again. A simple reduction to an hourly service (as has happened many times in the recent past) would bring the parish’s final score easily within the range of to a Tier Four settlement rather than justifying re-allocation to Tier Three. This is absurd and could end up being the reason why development is guided towards Brightwell cum Sotwell. BCS would urge SODC to reintegrate its own data and to reconsider whether a score of 10 for Brightwell cum Sotwell is any where near appropriate. Placing a score of 10 gives far too great an weight on the current yet variable service provision for the purposes of the JLP that could change at any time.

The Settlement Assessment and Hierarchy Topic Paper provides a score of 54 for the parish regarding level of services and infrastructure. BCS considers that this scoring however is flawed for a number of reasons that have not been justified in the Topic Paper.

With the best will in the world, BCS has used the same criteria that were used in the Topic Paper (and the same weighted system) to try and work out how a score of 54 was reached. Having carried out our own analysis several times a score higher than 34 simply cannot be reached for the main settlement of Brightwell cum Sotwell. When the outlying settlements are accounted for, this number does increase (a figure of 54 however still is not reached), however this does not account for their position in the parish being separated from the main village by some considerable distance. Shillingford Hill and Rush Court for example are only connected by travelling to the centre of Wallingford and back out again!

Further incorrect assumptions must have been made in the Topic Paper to reach a score of 54. For example, the village has 4 churches (one CoE church however is no longer used for regular worship). Of these churches, 2 are ‘closed’ churches used by distinct communities made up from a much wider geographical area. This type of facility should not be considered as a village service for the purposes of this study. Even with this type of service being considered, BCS still cannot deliver a total score anywhere near 54!

Even the Preferred Options Paper itself supports this view. Policy TCR1 (Centre Hierarchy) has considered those villages that provide the infrastructure to be considered as a local centre. This assessment includes nearly all of the settlements that are considered in Policy SP2 to be a Tier Three

village but significantly does not include Brightwell cum Sotwell. Whilst our settlement does have a church, a shop, a pub, several public open spaces etc, the level of facilities are far more akin to a Tier Four village. For this reason alone, re-allocation to Tier Three should be rejected.

For many of the daily requirements that a Tier Three settlement should provide, in Brightwell cum Sotwell this is simply not the case and for the reasons set out above necessitates leaving the parish and for most of the village this means travelling by car.

For these reasons, BCS would challenge its services and infrastructure scoring of 54 in the Settlement Assessment and Hierarchy Topic Paper – we simply cannot see how this has been reached when our own analysis cannot return a figure higher than 34.

It is assumed that the village also has a scoring of 4 for its broadband connection – this was hard fought for and in the view of BCS simply should not now be used in the way that it is. It is Government Policy for all communities to have access to faster broadband – BCS considers that by placing such a high scoring to this is unjust.

It is significant that Brightwell cum Sotwell returns a Proximity Score of zero.

BCS would ask for Brightwell cum Sotwell’s historic development to be considered in the assessment criteria. The parish is an amalgamation of three former parishes with many outlying settlements that are distinct and separate from the main village area (although forming a significant part of the overall population). Whilst being a much cherished and vital part of the parish, any facilities within these places cannot be considered as contributing to those of the main settlement. It is assumed that this has to be the case for a score of 54 to have been reached.

BCS would also argue that the assessment criteria that underpins the proposal to reallocated the village to a Tier Three does not take into account any local circumstances, policy or community aspirations. The Topic Paper itself admits that it based purely on a desk top tick box exercise. At some point, a decision had to have been made as to whether or not Brightwell cum Sotwell should be reallocated based on (in the opinion of BCS) a flawed process. BCS would urge SODC to reconsider this and to take into account other factors (set out below) that have to be relevant when making such an important decision that will affect our community for decades.

The Brightwell cum Sotwell Neighbourhood Plan (NP) places its most significant emphasis on retaining the character of the main settlement as being one that is characterised as rural with winding lanes, leafy gardens and protected rural open spaces (that are located within the village boundary) that is distinct and separate from Wallingford. The NP builds on the Community Led Parish Plan that surveyed every householder in the parish. Both the NP and CLPP demonstrate and provide evidence as to why the village considers itself as a distinct, vital and small rural community – the retention of this character being our number one priority.

This objective should be considered alongside the way that the parish has planned for growth that retains and strengthens this special character. The Topic Paper and the scoring used to reach its settlement hierarchy simply does not account for this type of consideration. It is the view of BCS that unless these wider considerations are taken into account for those settlements (in the view of BCS wrongly so) that sit so close to the threshold for re-classification, the methodology is flawed. The decision is too significant not to. Some degree of flexibility has to be considered.

In terms of character, Brightwell cum Sotwell has far more in common with Tier Four villages than those in Tier Three. Indeed, it could be argued that Brightwell cum Sotwell’s character is similar to some of the settlements that are now no longer classified at all!

Brightwell cum Sotwell’s character, topography, environment and facilities all lend themselves to being a Tier Four settlement. Based on the views of local people, residents consider themselves as living in a small rural community (the most important thing to villagers when surveyed as part of the current Community Led Parish Plan). The Parish however, recognised the need for some planned growth to sustain our vital village. This has been achieved through our neighbourhood plan in a way that has not altered the established character or the way that the village sees itself (as a small rural community). Significantly, this

development was on the whole, entirely consistent with a Teir Four settlement in that it was largely placed on land that was formally used for a different purpose than open countryside or farmland- allocated sites being on land that was locally considered as brownfield (former nurseries, derelict farmyards etc).

It is significant that the village returns a low score for a Tier Three village, at 64 (note that BCS strongly disputes this score as set out above), this being only 4 points above the threshold. This score is made from the village’s broadband and bus route provision set alongside our services and infrastructure score that appears to include facilities based in settlements outside and disconnected from the village but within the parish.

With a more realistic services and infrastructure score (including broadband provision) even when the bus route score is considered this would not bring Brightwell cum Sotwell above the threshold for inclusion in Tier Three.

Tier Three villages lie within a score range of 60 to 190. This places Brightwell cum Sotwell alongside communities such as Benson, Berinsfield, Cholsey, Sonning Common and Woodcote (within the SODC area). A simple analysis of these settlement’s character, services, facilities, community outlook and so on would demonstrate why these places are so different to Brightwell cum Sotwell. This has to be accounted for when making such a decision.

A tier Four village scores between 30 and 60. Other Tier Four villages within the SODC area include Aston Tirrold/Upthorpe, East Hagbourne, Stoke Row, Warborough and Dorchester. BCS would strongly argue that Brightwell cum Sotwell has far more in common with these settlements than those in Tier Three – both in terms of character, outlook and in level of services and facilities. We simply cannot understand why we have been singled out.

To conclude, BCS can find no justification for the settlement to be reclassified as a Tier Three village. BCS would challenge the scoring placed on the settlement in the Topic Paper and the weight that is placed on several criteria particularly the bus service (based on the nature of the village as set out above). A facilities and infrastructure scoring of 54 cannot be justified – BCS would ask for a meeting to discuss this as the consequences of it are far reaching. A realistic score of 34 (20 points below that reached in the paper) has been reached by BCS – easily bringing Brightwell cum Sotwell well below the threshold level.

In addition, the Topic Paper clearly states that ‘We fully recognise that all places, regardless of size, role and category, are important to those that live and work in them and this assessment is not intended to categorise settlements in any way other than with regard to their facilities and function’. From this it can be assumed that despite Brightwell cum Sotwell being only just above the Tier Three threshold, no consideration was given to character, community led planning or neighbourhood planning when deciding that the village should be re-classified. This also has to be cjhallenged when making such an important decision.

The tier that any settlement is placed in has consequences. BCS is particularly concerned that if reclassified as a Tier Three settlement, inappropriate growth could be directed towards the parish in that the Preferred Options paper looks towards ‘guiding new development to Science Vale, to our Garden Communities and to locations in the highest tiers of the settlement hierarchy (Tiers 1, 2 and 3) as set out in Policy SP1. In smaller settlements in Tier 4, some more specific brownfield development is also appropriate within the built-up area. This helps to reduce the need to travel and help people shift towards more sustainable travel patterns’.

This is deeply worrying and smacks in the face of a community that works hard to retain its facilities whilst playing its role in helping SODC meet its housing target. Moving the village to Tier Three could potentially destroy everything that the village has worked so hard to achieve including our very identity and soul as a community.

For the reasons stated, Brightwell cum Sotwell Parish Council would therefore strongly ask for the JLP to retain Brightwell cum Sotwell as a Tier Four settlement.

Policy CE5 Renewable Energy

The JLP suggests that it is looking to identify suitable locations for renewable energy infrastructure. This policy should be linked to other policies regarding landscape protection and ensure that any identified site does not become a future brownfield site that could be considered suitable for development. Local Neighbourhood Plan (NP) policies should be accounted for.

Policy CE6 Flood Risk

This preferred option looks at building resilience to minimise the impact of flood risk. BCS would ask the council to consider whether this could go further in identifying ways that natural flood risk management schemes could help achieve this through wetland creation and measures to attenuate flow. These measures would help to achieve the goals identified in other policies of this plan (nature recovery, landscape, carbon storage etc) and provide measures that SODC could deliver that would have regional benefits. The proposal also links directly with the Environment Act 2021 creating places that have multiple benefits for people, wildlife, water and recreation in agricultural locations at risk from climate change.

Policy CE10 Light Pollution and Dark Skies

BCS strongly supports this new policy and congratulates the Council for its inclusion.

Policy HOU12 Rural and First Home Exception Sites

This policy, whilst supported should provide clarification as to what the scale of growth is considered appropriate. In addition, the policy does not account for those settlements (such as Brightwell cum Sotwell) that have planned for development growth that includes a higher proportion of affordable housing (based on a Housing Needs Survey). Inclusion of such a clause would ensure that exception sites are not used by landowners as a backdoor to achieve speculative development by stealth. This is particularly important in a district that has high house prices and that the proposed policy suggests that some market housing provision could be included to make affordable houses achievable. At the very minimum, the policy should mandate an independent housing needs survey (based on ORCC guidelines) to support any proposal and should also consider any community aspirations set out in parish Neighbouring Plans.

BCS would also consider that this policy should be extended to Exception sites for elderly people – for the same reasons set out above.

Policy DE5 Neighbouring Amenity

BCS strongly supports this policy.

Policy HP10 Water Courses

This policy could be linked to policy CE6. There seems to be no connection between the two policies. Opportunities for wetland creation and natural flood management should be supported.

Policy NH1

BCS strongly supports this policy.

Policy NH3 Trees and Hedgerows

BCS would ask for the contribution of existing areas of scrub to be considered (in its significance in providing cover and habitat within a mosaic of habitats) to achieve nature recovery.

Policy NH4 National Landscape

BCS would consider that the policy to protect the setting of nationally designated landscape be strengthened particularly in light of the planned growth set out in the JLP. In particular, views to and from national landscapes (during the day and at night) should be considered. BCS would ask whether the JLP could consider designating National Landscape Setting Zones – establishing those places that are intrinsically interlinked with nationally designated areas – culturally, through wildlife, historic, geological and recreational activity. This could be linked with policies supporting recreation and active transport.

In Brightwell cum Sotwell for example, the link between the Sinodun Hills and the former marshes surrounding the village, ,Mackney, Moretons and Cholsey is significant.

Policy NH5 Landscape Coalescence

BCS is concerned that this policy does not offer sufficient protection to stop coalescence through stealth – in that development deemed appropriate for open countryside could be permitted. Local designations included in made neighbouring plans known as ‘Gap Policies’ should be provided for in the policy.

Policy HS6 Valued Landscapes

BCS would ask for provision to be made for parish councils and local communities to be an active part of the landscape assessment process that the JLP proposes. In addition, it is important that provision is made, in policy, for local considerations set out in neighbourhood plans to be considered.

Policy NH8 Historic Environment

BCS would ask the JLP to consider a specific policy regarding the importance of the Sinodun Hills at the centre of the geographical area included in the plan. A local designation to support the protection, celebration and enhancement of the regionally important landscape would have benefits that could be linked to many other policies in the plan and would provide the JLP with a locally innovative policy based on the specific character of the place. The historic and cultural importance of the Sinodun landscape (including the intrinsically connected flatlands below) have a nationally important role in the nation’s history and cultural identity from the Bronze Age to the present. BCS would look for this to include a landscape masterplan for the area, setting out its historic development, archaeologic potential achieved in a way that makes recommendations for future multiple benefits (NFM, habitat creation, recreation, tourism etc) that the landscape and its celebration could bring.

Policy NH9 Historic Assets

Locally designated Heritage Assets, as set out in Neighbourhood Plans need to be considered and ways to protect these set out.

Policy IH1

BCS would ask for clarification in the JLP on the way that bypasses form an artificial boundary to a settlement that often do not sit comfortably in the historic grain of a landscape. This is particularly so when used as a means to define the edge of settlement growth.

IN5 Parking

The JLP should make provision for future ways that electric parking charging points for domestic housing within villages should be located and designed. This is something that Brightwell cum Sotwell is currently investigating – in that our community has many houses that use on street parking within a historic location. There are no street lights or controlled parking measures making the siting and design of charging points particularly challenging.

BCS would also ask for greater clarification regarding the use of village front gardens for parking to be considered to conserve the character of village settlements.

We trust that these comments can be considered.

Jason Debney
On behalf of Brighwtwell cum Sotwell Parish Council