Oxford City is consulting on future housing numbers.  This will dictate levels of development not just in the City but in surrounding Districts too.

See: https://consultation.oxford.gov.uk/planning-services/oxford-local-plan-2040-reg-18-part-2-consultation/

Closes 27 March 2023.

We say “Need not greed should drive Oxfordshire’s future”

Oxfordshire Housing & Economic Needs Assessment – An NNGO Analysis

Oxford City Council’s approach is based on a new piece of work looking at future housing and jobs numbers, jointly commissioned with Cherwell District Council.  The Oxfordshire Housing & Economic Needs Assessment (HENA, Dec 2022) has been produced by Cambridge Econometrics and Iceni, the very same organisations that previously drew up the deeply flawed ‘OGNA’ (Oxfordshire Growth Needs Assessment, July 2021).

1. Left unchallenged, the HENA is likely to dictate housing numbers across the whole of Oxfordshire.

The City says it will be up to other local authorities whether or not to follow these figures.  However, if they are agreed by a Planning Inspector and embedded in either the Oxford City or Cherwell Local Plans, then it may be very hard for Oxfordshire’s other local authorities to fight a rear-guard action against them.  If these figures are to be challenged, then our local authorities must act NOW.

2. These companies have a track record of over-estimating.

The ‘transformational’ figures in their previous analysis (the OGNA) suggested that the number of jobs in Oxfordshire would increase by 171,200 by 2050, we would need one new house for every two that we have now and around 11,000 net migrants into the County every year for 30 years.  When NNGO questioned this assumption and the level of net migration assumed, we were dismissed.  However, now this trajectory is rightly rejected in the HENA as being over-optimistic.

3. The new projected growth figures are still wildly exaggerated.

Oxford City is proposing to use the trajectory underpinned by a special Cambridge Econometrics (CE) model outlined in the HENA.  This puts the Oxfordshire-wide need at 4,406 dwellings per annum.  This trajectory would expect to see Oxfordshire’s population growing by nearly 27% by 2040, compared to Office for National Statistics estimates of a UK population increase of less than 5%.

4. The figures are not based on the Government’s Standard Methodology. They arbitrarily extrapolate conclusions from the 2021 Census.

NNGO agrees that the Census figures for Oxfordshire show that our population has grown faster than predicted (not surprising given the Oxfordshire Housing & Growth Deal, by which our local authorities agreed to a level of housing development well above local need).  However, population figures are not the same as household projection figures.  The Census indicated that household numbers in Oxford actually dropped slightly from 2011.

Our view is that the Government’s Standard Methodology remains the upper limit of what would be acceptable in terms of housing growth (3,388 dwellings per annum, compared to the 4,406 dpa proposed).  Even this will place significant strain on our environment, services and infrastructure, and a trajectory based purely on meeting affordable housing need should be considered.

New standard methodology figures are expected in 2024, when the ONS’s household projection figures based on the 2021 Census are due to be published. Further census data still to be published also includes information on commuting, household formation and student numbers. Until then, a highly precautionary approach is required.

5. The growth is based on carrying forward recent high levels of growth in perpetuity.

The population projections assume that comparatively high net migration rates into Oxfordshire during the five years 2015-2020 – 2,752 per year – will continue for the next 20 years.  Given our current economic difficulties, this remains unlikely (see pt 2).  It would certainly be more reasonable to base the projections on the ten-year period from 2010 to 2020 – this is 2,287 a year, 17% less.

6. Overall, the HENA conclusions on growth are not compatible with the Oxfordshire Strategic Vision which commits all our authorities to planning for ‘good growth’ that is both sustainable and inclusive.

What is the associated carbon budget, both embedded and ongoing, for this level of growth?

What are the implications for Oxfordshire’s emerging nature recovery strategy?

How will off-loading growth onto surrounding Districts impact on the County’s Transport Strategy and the commitment to reducing car journeys?

Overall, the planned growth would have major consequences for Oxfordshire’s environment and quality of life and for the overall Levelling Up agenda, since it is based on pulling in migrants from less affluent parts of the UK.

What should happen now?

Our other local authorities (South Oxfordshire, Vale of White Horse and West Oxfordshire District Councils) must be prepared to engage robustly in the Cherwell and City local plan process.  NNGO calls on them to immediately commission an independent review of the HENA and to set out their own alternative vision for sustainable housing growth in the county.

What can you do?

1. Respond to Oxford City’s consultation – you can fill in the online survey or simply email planningpolicy@oxford.gov.uk
2. Please alert your District/City Councillor to the dangers embedded in the HENA. If you live in Cherwell or the City, please ask them to reconsider their approach.  If you live in one of the other Districts, please support them in making a robust challenge to the HENA growth agenda.

The template letters below may act as a guide but would be much better if put into your own words.

If you don’t know who your councillor is, then you can easily find out at www.writetothem.com

Template letter to Councillors

Template letter to Cherwell Councillors

Template letter to South Oxfordshire, Vale of White Horse, West Oxfordshire Councillors

The punitive 5 Year Housing Supply rules have been the source of much inappropriate development in Oxfordshire over the last few years and continue to be a very real threat.

These rules state that if a local authority cannot prove it has a 5 year deliverable supply of housing, then it becomes much harder for them to refuse speculative applications.  This has put our countryside and rural communities under pressure and led to some highly inappropriate developments being approved against the wishes of local residents/District Councils.

There is now a chance to get these 5 Year Housing Supply rules abolished.

The Levelling Up & Regeneration Bill is currently going through parliament.  An amendment has been put forward (NC21, tabled by Rt Hon Theresa Villiers MP), which would require a revised National Planning Policy Framework within six months to provide that housing targets are advisory not mandatory and that the five-year housing land supply rule will no longer apply.

This is a critical opportunity. 

Please write to your local MPs to urge them to support this amendment. If you don’t know who your local MP is, this site can help: www.theyworkforyou.com

NNGO has prepared a template letter you may like to use, download it here. 5 Year Housing Supply Template Letter

Oxford City Council is consulting on its Local Plan through to 2040.

Last time round, its aggressive growth ambitions resulted in 15,000 houses being offloaded onto the countryside of the surrounding Districts.  This is putting pressure on local communities and impacting Oxford’s transport infrastructure and green spaces, but fails to provide truly affordable housing.

We need lots of people to tell them NOW – we want development to cater for NEED not GREED.

How Can You Respond?

Email your views to planningpolicy@oxford.gov.uk by Monday 14 November

Key points to raise

It is very important that you express your views in your own words, in your preferred order and in your own style.  The first point below is fundamental and we encourage you to include this along with other points that you feel are important.

1. If you only tell them one thing please tell them this!                                   

The housing figures should be set at the minimum that it is possible to achieve whilst meeting genuine need.  (Policy sets H1 and H2 – Housing Need & Requirement)  Exceptional circumstances (eg the climate, biodiversity and health emergencies, democratic wishes of districts, truly affordable homes, UK’s urgent need for Levelling Up, the constraints of flood plain and Green Belt, the over-delivery in relation to need already accommodated within the Oxfordshire Housing & Growth Deal) are all logical reasons for a housing figure that is below that produced by the Standard Methodology.  Housing figures above those produced by the Standard Methodology cannot be justified because of the overriding importance of our climate and nature emergencies and the constraints on delivery within the City.

2. The City should constrain itself to what is deliverable within its own boundaries, maximising sites for housing rather than employment. (Policy sets H1 and H2 – Housing Need & Requirement)

3. A further Green Belt Review is not required. (Policy Set S2: Approach to Greenfield sites)

The main purpose of the Green Belt is its openness and permanence.  Permanent boundaries have just been set in the last tranche of Local Plans. With 20,000 houses and other development already planned for the Green Belt, such a review would be premature and a waste of taxpayers’ money.

Further information

You can find the Oxford Local Plan 2040 Preferred Options document (the housing information is in Chapter 2) and all the details about the consultation itself –- on the City Council website.

Our suggestion is that you don’t respond using the online questionnaires because of the extent of the leading questions. Just email planningpolicy@oxford.gov.uk

NNGO’s full consultation response includes more detailed comment and background information that could help with your own reply.  

 PLEASE ACT NOW

This is the best chance we have of influencing the emerging Plan.  We therefore also ask you to encourage as many as possible of your colleagues/friends to respond.  We need Oxford City Council to understand the widespread opposition to it carrying on as before, setting unrealistic and inappropriate housing targets that it expects its neighbours to meet.

The focus must not be on pursuing arbitrary growth targets, but on providing the affordable housing that is genuinely needed in as sustainable a way as possible.

Need Not Greed Oxfordshire (NNGO) has responded forcefully to the City Council’s current Preferred Options consultation on its Local Plan to 2040.

NNGO is seeking to remind residents that in the last round of local plans the City’s aggressive growth ambitions resulted in 15,000 houses being foisted onto the surrounding Districts. These allocations were mainly in the Oxford Green Belt – whose purpose is specifically to set limits on the expansion of Oxford in order to protect this historic city.  These new housing developments, many of which aren’t yet built are already putting huge pressure on local communities, infrastructure and services.

NNGO member Ian Ashley commented:

“The City is seeking to plan housing to support an increase in workers.  We think it should prioritise scarce land to provide truly affordable homes for people who already work in the City. Beyond that, housing growth should be constrained due to the climate emergency, loss of biodiversity, the democratic wishes of the Districts and the UK’s urgent need for Levelling Up by creating jobs where people already live.” 

 NNGO member Suzanne McIvor disagreed with the City Council’s assertion in the Preferred Options that addressing inequalities can only be achieved by “supporting the economy, delivery of sufficient housing and provision of affordable housing”.   She said:

“The City Council acknowledges in the same document that a growing economy can result in more pressure on the housing market and exacerbate issues with affordability.  Attracting more people from elsewhere to work in the City is not the answer.  What is actually needed are truly affordable homes such as council houses“.

NNGO’s concerns relate to three main areas.

1. NNGO is highly critical of the Preferred Options consultation document, which it claims is not fit for purpose because it fails to set a housing target and therefore can’t provide meaningful spatial options for people to comment on.  NNGO also condemns the complete failure of the Council to take account of responses from an earlier consultation where public opinion was overwhelmingly in favour of safeguarding the natural environment and its wildlife habitat and preserving open spaces. NNGO believes this is an unacceptable failure of process – and is disrespectful to those who took the time to respond to the previous consultation.  NNGO also urges residents not to respond to the consultation via the online questionnaires, which it says include too many leading questions designed to elicit responses to support the City’s preferred outcomes. 

2. NNGO claims that the City Council is out of touch with the concerns of its residents in pursuing a continued high economic ‘growth at any cost strategy’, which it says could lead to an urban sprawl eventually encompassing Witney, Thame, Bicester, Kidlington and Abingdon.  In addition the City’s approach fails to address the overarching climate and environmental imperatives.  NNGO is also clear that there is no evidence that simply building more houses reduces house prices.

NNGO is looking to an alternative vision of prosperity with less expansive growth; by building houses that are really needed within the urban areas. They claim this vision is much more in keeping with the need for levelling up – and NNGO challenges our world famous University and Colleges to turn their attention away from pressuring local land development (and seeking windfalls on the land that it owns) to working with the regions that would benefit from economic growth.

3. NNGO wants the City Council to set the housing figures at the minimum it is possible to achieve. NNGO say that exceptional circumstances (from the climate, nature and health emergencies, the democratic wishes of the Districts, the need for truly affordable housing, and the UK need for levelling up, to the special local environment of Oxford) demand that the City Council should seek a housing figure that is below the Government’s Standard Methodology.

Ian Ashley added.

“NNGO considers it crucially important that the general public and elected councillors in the Districts surrounding Oxford challenge the City Council as it develops this local plan; as we know an ill-considered Plan with inflated housing figures will have far-reaching, significant and detrimental effects for Oxford and beyond.

We have specifically asked the City Council for reassurance that it will not be using the same consultants that produced the flawed housing forecasts for the now abandoned Oxfordshire Plan 2050.  We would also like confirmation that the consultants who prepare the housing forecasts are not conflicted by being overly reliant on developers for the majority of their income”. 

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 The full response from NNGO on the Oxford 2040 Plan can be read here.

The Preferred Options consultation document can be found on the Oxford City Council website.
Housing is covered in Chapter 2.

Nine months since the last consultation on the Oxfordshire Plan 2050 closed, there has been no
public progress on the Plan. This spatial plan for Oxfordshire is important because it will cover
development in the County for the next thirty years and will need to be approved by the City and
District authorities. NNGO is asking – what is going on?

Where is the project timetable?
A decision on the level of housing growth to be embedded in the Plan was initially due in December
last year. In January, it was said ‘officers are reviewing the work programme and timeline for the
Oxfordshire Plan … and we aim to conclude that review soon’.
There is still no published timetable.

What is the OP2050 team currently working on?
Where is the scrutiny? How much money is being spent on an OP2050 team that is working behind
closed doors?
How can they be developing a spatial strategy without agreeing the number of houses to be built?
Or, if they have decided on the level of housing growth already, why has this decision not been
made openly and transparently?
There have already been failings in the Councils’ Scrutiny process. Bringing the next version of the
Plan to councillors for sign off at the last minute, when the work has already been completed and
there is no realistic prospect of any amendments, is unlikely to be acceptable to Oxfordshire
residents.

How will criticisms of the growth options be addressed?
NNGO, together with other respected community groups, has criticised the figures being used to
dictate proposed housing levels and called for an independent Peer Review of last year’s housing
assessment, known as the Oxfordshire Growth Needs Assessment.
NNGO was told a decision on this would be taken after the summer 2021 consultation responses had
been reviewed. The response report was published in January but there is still no decision on a Peer
Review.
Meanwhile, an independent review by experienced housing market consultants, Opinion Research
Services (ORS), commissioned by Cherwell Development Watch Alliance, has reinforced fears the
methodology used does not stand up to scrutiny. It found:
“The unjustified use of adjustments made to official projections and the Standard Method together
with the lack of a conventional central economic forecast call into question the soundness of this
document as supporting evidence for the development of the Oxfordshire Plan”.

Should there be a re-run of last year’s consultation?
NNGO would support a re-run of this consultation (known as a Regulation 18) with the public given
clearer information and genuine choices about levels of housing growth.
What is the Future Oxfordshire Partnership (FOP) doing?
The FOP, made up of all our local authorities, is supposed to be in charge of this process through its
Oxfordshire 2050 Advisory Group. However, questions to the FOP are deflected with meaningless
statements. It has even failed to address the advice of its own Scrutiny Panel which said a project
timetable, a peer review of the growth evidence and a new consultation were all needed.

The next FOP meeting is on 13 June. NNGO will once again be seeking answers to the above
questions.

The Oxfordshire Growth Needs Assessment (OGNA) forms the basis for the preparation of the Oxfordshire Plan 2050 (Oxon2050). It is vital that it is soundly constructed. An independent, impartial review commissioned by Cherwell Development Watch Alliance questions the soundness of the OGNA as a basis for the development of Oxon2050.

CDWA commissioned an independent review of the OGNA by a specialist in Housing Market Assessments: Opinion Research Services.

ORS conclude that:  “The unjustified use of adjustments made to official projections and the Standard Method together with the lack of a conventional central economic forecast call into question the soundness of this document as supporting evidence for the development of the Oxfordshire Plan“.

The OGNA is not a standard housing assessment which follows prescribed Government methodology.  Instead it predicts much higher population growth than recent Office for National Statistics projections for the County and especially the City of Oxford.

The summary, pages 4 to 6, exposes and explains the shortcomings of the OGNA which were previously hidden behind its complexity.

Review of the Oxfordshire Growth Needs Assessment ORS March 2022
Visit the CDWA website here.

Stop The Arc Group (STARC) created an alternative Arc Spatial Framework consultation with the Oxford POETS (Planning Oxfordshire’s Environment and Transport Sustainably) and with help and advice from a number of other concerned groups across the Arc. The consultation highlighted some of the hard choices that lie ahead – for example between development and the environment – and asked people how rapidly the Arc should grow.

Responders were not against growth, but wanted it limited to the average or below-average rate expected for the rest of country – a fair share, not a disproportionate share.

The results and comments show that the public is fed up with being kept in the dark about all Ox-Cam Arc plans. The official Government consultation document contained not a single word on the levels of growth in jobs, houses and economic output that this Whitehall-driven Arc plan involves. Nothing at all. Why is this? What is the Government afraid of?

Read more, including key findings, on the STARC website.

The alternative consultation remains open. If you would like to add your views please do so here.

Need Not Greed Oxfordshire is calling on councillors to do a ‘Kickflip Indy’ on the Oxfordshire Plan, and change direction to a lower rate of growth, to stay firmly on top of the environmental skateboard.

The campaigners say that even the lowest rate of growth proposed in the Plan (102,000 houses by 2050) would require such a dramatic increase in housing and population that a zero-carbon, sustainable future for Oxfordshire would be virtually impossible.

In particular, they have criticised the Oxfordshire Growth Needs Assessment (OGNA), a background paper which is supposed to provide the ‘robust and transparent’ evidence to support the various growth options.

David Young, from Greenway (an NNGO coalition member), said: “This document is complicated and obscure. We suspect that most councillors won’t have time to read it, let alone understand it.  Far from being robust and transparent, it seems to exaggerate the figures at every turn and then hide the impacts. 

“We believe that to use the Oxfordshire Growth Needs Assessment as the basis for planning for the county for the next 30 years would be entirely inappropriate.  We think the only solution now is an independent peer-review of this document which is not fit for purpose.

“We are calling on the councillors and officers involved in the Oxfordshire Plan 2050 team to act quickly to put such a review in place.”

The public consultation on the Oxfordshire Plan 2050 ends on 8 October.  NNGO is urging all Oxfordshire residents to have their say.

The Oxfordshire Plan will set the development framework for the county for the next generation. It will affect all Oxfordshire residents.

Take a look at the NNGO flyer above or download here and read our concerns about the Oxfordshire Plan 2050.

Want to have your say in the future of Oxfordshire?

Here’s a template email which you can cut and paste, feel free to change it to make it your own and to cover your specific concerns eg Green Belt, infrastructure, water quality.

SEND TO:  info@oxfordshireplan.org

DEADLINE: 8 October

If you have a further minute, please share your email with your Councillors and MP and let them know that you do not agree with the options presented in the Oxfordshire 2050 Plan. You can find out who to contact here: www.writetothem.com

Dear Oxfordshire 2050 Team,

Preferred Policy Option 28 on Homes states:  ‘Through this consultation on the Regulation 18 Part 2 stage of the Oxfordshire Plan, the scenarios for the total housing requirement figure 2020-2050 (the OGNA) need to be considered and views are sought’.  My views are as follows:

I would like to see the total housing requirement set at the lowest possible figure, preferably lower than the Option 1 Standard Method, which is still substantially above that needed to cater for the existing population.

I am deeply concerned at the current and proposed levels of development in Oxfordshire and the plans to supercharge the growth of the county as traditionally measured.  This will result in many more people moving into the area requiring ever more houses, roads and traffic. This scale and pace of development, replacing countryside with concrete, is completely inconsistent with our declared climate and nature emergencies.

The housing growth option in the 2050 Plan described as ‘business as usual’ is actually continuing an exceptionally high growth plan which is set to transform much of our landscape over the coming years and will enable house builders and land owners to profit at the expense of the quality of life of existing residents.

There should be an option for Oxfordshire to grow organically, based on up to date natural population growth numbers produced by the Office for National Statistics, with the focus on making housing in the area more affordable. Policies on restricting buy to let and introducing a land value uplift tax would be good. Policies enabling housing association and council houses on brownfield sites would also be enormously helpful.

I also want our Council Leaders to resist any attempts by central Government to impose an increase on the number of houses to be built in Oxfordshire as part of the OxCam Arc proposals. 

Local and by-election results over the last couple of years suggest that a great many members of the public share these concerns and I would ask that you and our elected representatives robustly engage government to rethink its strategy for Oxfordshire and focus instead on their election promise of levelling up the UK – creating jobs where people already live.

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