CPRE urge SODC to prepare a new and better Local Plan for the District’s future

Hulton Park

1st October 2019

In a letter to South Oxfordshire District Councillors CPRE Oxfordshire suggest that the new administration should prepare a new Plan at its own pace with proper levels of development.


In a nutshell

SODC already has a sound Plan in place in the 2012-2027 Core Strategy and has no need to prepare a replacement now. The replacement you inherited from the last administration contains more than twice the houses even the Government thinks are needed and should be scrapped in line with the interests of the whole District, especially where election promises to do so were made. You are not obliged to provide for Oxford’s unmet need (if there is any) until after the City has bothered to prove it cannot meet its own needs, which it has not tried to do. The Government has no powers it could reasonably use to require you to keep the previous administration’s Plan and in the interest of the District and its residents it should be withdrawn.

Writing a new Plan will need to be started after 2020 to be ready for 2027 giving time for the Council to prepare a Plan of its own respecting the District and its residents and taking proper account of Climate Change and the need for sustainability.

South Oxfordshire does not need to produce a Plan of any kind now and neither did it under the previous Administration.

The Council already has a perfectly good and sound Plan – the Core Strategy 2012-2027. This has much lower housing numbers. No contentious Green Belt releases. No Chalgrove. Your officers confirm it is sound. Obviously, it will have to be replaced when it expires in 2027 which means starting work by 2020, but it is fine now. No new Plan at all is needed now. In 2020 the Council can start work on a replacement Plan in the form it wishes.

The “2011-2034” Plan inherited from the previous administration simply contains far more development in the wrong places than the District should be supporting.

To put that in perspective, the Government publishes official “projections” of housing need and its figure for South Oxfordshire for 2011-2034 is a requirement for 10,000 new houses. This fully reflects expected population growth and maintaining our high rate of economic development. The 10,000 new houses would increase the size of the average town and village by 20% or take open green fields on which to build. On top of this, the Government imposes a “standard method” which would require around 16,000. That is 60% more than are needed.

Against the 10,000 houses that are “needed” the draft Local Plan 2011-2034 proposes to build 23,000, and another 5,000 for “Oxford’s unmet need” (which we will come to in a minute) that is 28,000 altogether, or nearly twice the excessive number the Government forces SODC to plan for.

It would be a fifty percent increase in our total housing stock, more than twice the increase that we need.

Why would anyone be doing that?

Oxfordshire’s Councils have entered into a Growth Deal with Government whereby if as a whole they build 100,000 houses – more than twice the 48,000 the Government says are needed in the County –the Councils will get £215 million to support the infrastructure for the unneeded houses.

Matthew Barber, the ex-Leader of the Vale, said that the £215 million on offer wasn’t enough to provide the infrastructure for the extra houses Oxfordshire didn’t need but all of Oxfordshire’s Councils pressed on anyway, lured by the money.

It is reasonable to think that the unpopularity of this scheme played a large part in the recent Council elections with larger than national swings sweeping away the previous administrations in Vale and South Oxfordshire and decimating the administration in Cherwell which only had a percentage of seats up for election.

That is why the new administration is right to have campaigned against the Growth Deal’s Faustian pact with the Government.

Apart from having no public support what harm would the Growth Deal housing numbers in the draft Plan do?

If the new houses are built and occupied the increase in population will place yet more burden on already hard-pressed infrastructure and services, including doctors and schools; unnecessarily concrete over the countryside and Green Belt and strain the cohesion of towns and villages.

If they are not built – and given they are more than twice the number needed, and developers won’t build houses they cannot sell, this is almost certain – the Council will lose its five year supply (if the Council cannot continuously prove it is building the number of houses it has planned to do, the Government exposes it to predatory developers or ultimately takes away its control of planning entirely).

Because the existing Core Strategy (see paragraph 1) has lower housing numbers it has a very comfortable ten-year supply. On the other hand, even your officers (who advocate the new Plan) agree that the new plan is high risk.

If SODC reduces the housing numbers won’t it lose its share of the Growth Deal money and the Housing Infrastructure funds?

Probably yes – but then it won’t be building the houses and won’t need the money – which in any case was inadequate for the purpose.

Will other Councils be affected?

It is very unlikely that the Government would not agree to continue to incentivise the other Councils to concrete over their District unnecessarily. West Oxfordshire’s administration has already adopted a Local Plan pledging to do so. Although Cherwell lost a number of seats at the last election, the administration has not changed and is determined to press on regardless.

Under its previous administration the Vale has already adopted a Plan to build 20,000 houses (over twice the 9,000 the Government says it needs). We are hoping to persuade them not to adopt a follow up Plan for 2,200 houses for Oxford’s unmet need (we are coming to Oxford’s unmet need in a moment).

The Vale says that its development at Valley Park Didcot will be jeopardised if SODC scraps the proposed new town on the Green Belt at Culham and therefore does not get Housing Infrastructure Funding for it.

But the Vale’s Valley Park development was in a Plan adopted before the concept of Housing Infrastructure Funds was even thought of. The Vale’s real problem is exactly the problem SODC would have if it adopted the draft Local Plan – planning to build too many houses is a sure recipe for failing.

What about Oxford’s unmet need?

“Unmet need” arises when a Council has identified that its own housing need cannot be met within its boundaries. Surrounding Councils then have a duty to co-operate in helping. National Planning Policy requires the Council with the unmet need to leave no stone unturned in trying to accommodate it, including a diligent search for sites and using higher densities. And the Council’s conclusions must then be rigorously tested, for instance at a Public Examination.

None of this has been done and therefore the allocation of 4,950 houses “unmet need” to South Oxfordshire is unsound and there is no “duty to co-operate” with an unsound figure. For the same reason there is no justification for building them in the Green Belt as an unsound number cannot be the “exceptional circumstance” required.

The Inspector at the Vale said the process of estimating Oxford’s unmet need had been “robust”, but this did not include the outcome which he called a “working assumption” (that is, an initial estimate expected to be wrong).

How wrong? The original SHMA gave Oxford a spread for total housing need of between 24,000 and 32,000 houses. Since the number of houses Oxford can build is fixed (even though they have not yet satisfactorily quantified it) that means that the total unmet need, guessed to be 15,000 for planning purposes, could be anywhere between 7,000 and 23,000.

On top of which CPRE has shown in detail that if densities were increased to levels appropriate for a City, and if all available land was used for housing, then Oxford would be able to accommodate its whole housing need and there would be no unmet need at all.

Project Fear

You may have heard that if you do not continue with the previous administration’s grossly overblown and damaging Plan the Government may intervene to force you to do so. Whilst the Government does in the end have statutory powers to hand control to another Council this is highly unlikely here. One of the examples quoted is York – but York has not had a Local Plan at all for the last 32 years and is still only being threatened with such action.

South Oxfordshire already has a Local Plan – the Core Strategy 2012-2027 – and in any case is fully ready to prepare a new one in due course.

In summary

  • The numbers in the previous administration’s 2011-2034 Plan are grossly overstated in relation to need and certain to lead the Council into “five-year supply” problems and to the loss of planning control altogether.
  • The Growth Deal and other funding generally only applies to the developments which should in any case not proceed, both in terms of the sheer numbers of unnecessary houses and the unjustified loss of Green Belt proposed.
  • “Oxford’s unmet need” is, to put it mildly, an unreliable figure needing to be resolved at the Oxford Enquiry in December. SODC should at the very least suspend consideration of a new Plan until after that.
  • In any case there is no requirement to do a new Plan at all as SODC have a perfectly sound one already to 2027. Work on a replacement does not need to start until 2020 at the earliest.

CPRE recommends that:

The draft Local Plan 2011-2034 should be withdrawn immediately from Examination, because the longer it is left with the Inspectors the more enmeshed the Council will get in questions forcing you to support it or withdraw it anyway.

The new SODC administration should prepare a new Plan at its own pace with proper levels of development, taking into account for instance climate change considerations for travel and housing location and confining itself as far as it can to the Government’s enforced “standard method” which is itself 60% higher than actual housing need.

We hope this information is of assistance and urge you to withdraw the current submitted Local Plan, with a view to preparing a new and better blueprint for the District’s future.