Vale of White Horse Local Plan Part 2 is unsound and it should be withdrawn

Hulton Park

16th September 2019

In a letter to Vale of White Horse councillors CPRE Oxfordshire say that at the very least the Plan should not be adopted until after the Oxford Local Plan has been examined and the City’s unmet need properly assessed.


Our suggested Way Ahead for the Vale.

It is too late to do anything about the catastrophe that the Part 1 Plan may cause except to as speedily as possible rewrite and replace it with a Plan better suiting the District’s actual needs and your vision for it.

It would be ill-advised to adopt Part 2 and compound the problems and it should be withdrawn, not adopted.

At least defer the decision until Oxford’s “unmet need” has been examined at their Enquiry in December when we are confident, for the reasons we show below, that it will prove over-blown or non-existent. In any case there will at last be a number – even if it is zero as we expect – in which you can have some confidence.

In a nutshell

The Vale’s total housing need (meaning housing that is actually needed to accommodate the current rate of population growth and economic development) is, according to the Government’s own household projections, for 10,000 new homes in the Vale during the Plan period 2011-2031.

The Local Plan Part 1 adopted in 2016 plans for 20,000 houses, twice as many as are thought to be needed. It is therefore hardly surprising that the Vale should be having difficulties with its five year supply as developers will not build houses for which they do not see buyers, and buyers will inevitably be in short supply if you are trying to build more houses than are needed.

The Local Plan Part 2 would add another 2,200 houses for “Oxford’s unmet need”. Whether Oxford has an unmet need to that extent, or indeed any unmet need at all will be covered later in this letter, but even if the total demand facing the Vale included 2,200 houses for Oxford, that would only increase the actual housing need to 12,200. Against which you are already planning for 20,000 homes in Part 1.

In other words, Part 1 already covers any unmet need Oxford may have. Adding another 2,200 homes to your burden as proposed in Part 2 can only make your five year supply position worse and therefore increase the likelihood of predatory development which Government Policy encourages.

On top of which the figure of 2,200 is little more than an educated guess which may be 100% wrong (as we show in this letter) and is far too flimsy a basis for a Local Plan, much less for removing land from the Green Belt at Dalton and Shippon.

The Vale therefore has no need for a Part 2 Plan at all, and it would be reckless to adopt it now.

The Part 2 Plan quite simply contains far more development in the wrong places than the District should be supporting.

The opening paragraph compared the 10,000 houses actually needed in the Vale according to the Government’s own Household Projections to the 20,000 the Local Plan Part 1 has planned for. Obviously building twice as many houses as are needed is a very stretching target and a recipe for disaster, as if you fall short the Government effectively allows developers to build where they wish and the Vale loses control of the planning of its area.

How you may wonder did this come about?

Briefly, the Vale together with the other Oxfordshire Districts, created a housing forecast – the SHMA – which used actual housing need as forecast by the Government as just one of the building blocks but then added the kitchen sink in terms of highly challenging assumptions about how much more housing demand businesses could create by encouraging new people to move to the Vale to take up notional future jobs.

What the Growth Deal was for

Recognising just how challenging it was to produce a Plan intending to build twice as many houses as were actually needed, the Councils across Oxfordshire, including the Vale, negotiated a Growth Deal with Government whereby the Government provided £215 million across the County to provide the infrastructure to support the building of the houses that didn’t need to be built.

Matthew Barber, Vale Leader at the time, said ‘we need significantly more investment than is currently being offered’ but signed off the Local Plan anyway.

HIF Funding – which we come to later – hadn’t been invented then so it was not assumed for the purpose of the numbers in Local Plan Part 1.

Where are we now?

The Vale already has a Local Plan Part 1 containing twice as many houses as the Vale needs. The Government now judges Plans against its new “standard method” of forecasting. That itself inflates the actual need figure from 10,000 to 14,000, but even against this measure the Vale Plan Part 1 has a surplus of 6,000.

The Local Plan Part 2 is for another 2,200 houses for “Oxford’s unmet need” but even including that there would still be a surplus of 3,800 houses (almost 20%) in Local Plan Part 1.

It would be foolhardy to add another 2,200 houses to your load when Part 1 already covers them and you already have difficulties supplying the Part 1 numbers.

Is Oxford’s “unmet need” real.

The SHMA – the everything but the kitchen sink forecast mentioned above – put Oxford’s total housing need at “between 24,000 and 32,000 houses”, that is almost a 30% margin of error. The Growth Board arbitrarily decided that Oxford’s unmet need was halfway between the two extremes, that is 28,000. Against that, the City claimed it only had the capacity to build 10,000. Other authorities challenged that and eventually the Growth Board arbitrarily decided that Oxford’s housing capacity was 13,000 houses leaving an “unmet need” of 15,000, of which 2,200 were allocated to the Vale. The consultants employed in this process, Fortismere, stated in their report that Oxford had not properly examined its densities, or its site availability, so its capacity might be greater.

That is the process the Inspector found to be “robust”, although he also said that the unmet need figure remained a working assumption (that is, a figure expected to be wrong when the facts were known) which needed to be tested at the Oxford Enquiry (this December).

On top of which, CPRE has looked at every site Oxford records and finds that (by following the requirements of Para 137 of the NPPF) Oxford could in fact accommodate all of the 28,000 houses the Growth Board has guessed it needs.

It is obvious that Oxford’s actual unmet need could be anything between 22,000 – if the high end of the SHMA had been used and Oxford’s claim of its own capacity had been correct, to 11,000 – if the low end of the SHMA had been used and the Growth Board’s assumption of Oxford’s capacity had been correct – to nothing – on CPRE’s detailed calculation based on densities appropriate to a compact City and using all Oxford’s available land for housing.

That means the figure is far too flimsy to be the basis of a Local Plan.

The Green Belt

Evidence as flimsy as the present guestimate of Oxford’s unmet need is especially inadequate when it comes to the Green Belt.

Local Plan Part 2 intends to remove a large swathe of Dalton Barracks from the Green Belt (along with Shippon which the Inspector had not appeared to intend).

To remove land from the Green Belt, exceptional circumstances have to be shown. In this case the exceptional circumstance is said to be Oxford’s unmet need; but that could ONLY be after the NPPF requirements – that it be proved by the City and tested at examination – have been met. As we show above, neither has been done.

There is no firm justification for any of the 2,200 houses proposed in the Part 2 Plan, and certainly none for releasing Green Belt land. Officers say ‘so what if we release it anyway, a need will appear eventually’. That is an unacceptably casual way to treat the Green Belt or any land in this rural District.

Project Fear

There is substantial pressure to “bounce” Councillors into adopting the Plan, the motives for which are not clear.

These include the Government taking over control of planning. Although this is a potential power it is rarely if ever used. York for instance has not had a Local Plan at all for over 60 years but despite threats the Government has not acted.

There are also threats to remove Growth Deal and Housing Infrastructure Funds. Of course if the Council decides not to proceed with the developments to which they applied, the Government can withhold some money.

But the vast percentage of the houses to which it applies are in the adopted Part 1 Plan so the risk is minor.

Can there be “too many” houses?

The purpose of the various Deals was to encourage the building of too many houses to attract more people to the area to grow the economy – forced industrialisation if you like – and the first stage of the OxCam Arc Growth Plan which would see the population doubled and the District and County changed beyond recognition. This is not only near vandalism in itself but the public have never been asked if they share this ghastly vision and almost certainly do not.

We hope you find this information helpful and urge you to support the withdrawal, or at least deferral of the Vale Local Plan Part 2.

The CPRE Oxfordshire letter to Scrutiny Committee 19-09-19 is attached below.

CPRE Oxfordshire Letter to Scrutiny Committee 190919