Oxford Local Plan Reg 19 Consultation, Jan 2024 – NNGO Response

Q4. Please tell us below why you consider the document to be unsound, not legally compliant or fails to comply with the duty to co-operate. If you do believe the document is sound, legally compliant, or complies with the duty to co-operate you may use the box to explain why.

Despite its title, this policy does not actually state the housing requirement.  Instead it refers to the capacity that Oxford City believes it has to deliver new dwellings within its existing boundary. In the accompanying text (para 2.8) there is reference to a housing ‘need’ of 1,322 dpa.  However, this figure of 1,322 dpa has not been derived from the standard method but from an alternative approach that has NOT been agreed with the neighbouring councils. This alternative approach produces a far higher housing target figure than the 762 dpa produced by the standard method. 

The difference between the standard method and the alternative method gives rise to an additional 560 dpa. This is very significant, particularly in the context of Oxford City where the additional dwellings will all represent ‘unmet need’ yet the majority of other local authorities have made clear their opposition to the HENA methodology behind it. The justification for the higher housing target of 1,322 dpa is claimed to be the exceptional circumstances arising from Oxford’s economic dynamism and growth performance.  But the standard method  already accounts for economic growth and also includes an uplift of 40% to reflect affordability issues.

Para 2.5 states ‘… the role of Oxford in the regional and national economy, are particular drivers of housing need……’. Rather than representing true exceptional circumstances this statement actually merely reflects the very high economic growth aspirations that the City continues to hold despite the fact that this further stokes housing demand and does nothing to make homes in Oxford City more affordable.  Oxford City Council also continues to allocate land to employment and market housing that could be used for council housing. The fundamental issue driving the housing affordability crisis in Oxford is the imbalance in jobs versus available, suitably priced, housing. A more appropriate solution to this problem could be to reduce the number of jobs in the City, not add to them.

We believe this submission draft is

1. Not  positively prepared.

a.    The housing need is based on spurious claims of exceptional circumstances which are not supported by agreements with surrounding local authorities.  Therefore Oxford City Council has not met the duty to cooperate.  South Oxfordshire District Council, Vale of White Horse District Council and West Oxfordshire District Council were all highly critical of Oxford City’s use of the Housing and Economic Needs Assessment (HENA) as (i) a means of preparing a figure for housing need and (ii) the proposed allocations across the districts.

b.   There has been absolutely no response to or engagement with the detailed feedback provided by multiple parties about the weaknesses of the HENA.

  1. Overriding issues around the environment and carbon zero are not simply to be addressed after a level of growth has been chosen but rather the determination of the properly sustainable level of growth should be absolutely focussed on them. We see no evidence of this having taken place, either in the draft Plan or the housing assessment underlying it.

2. Not justified.

  1. Many cities and countries around the world are recognising that giving primacy to economic growth, as this plan is doing, is not sustainable, has been to the detriment of the natural world and wellbeing of citizens and has been a key driver of the climate and ecological emergencies. An alternative, more appropriate approach, is outlined by economist Kate Raworth in Doughnut Economics which would balance economic, environmental and societal requirements of sustainability. 
  2. The housing requirement figures are not based on the Government’s standard methodology but an arbitrary and untested methodology created  by one particular group of consultants that have a track-record of vast over-estimation of growth and housing need. 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%. This level of growth is not consistent with the wishes of much of the electorate as witnessed in elections over the last few years.
  3. The draft Plan does not explain clearly how the housing need has been assessed and what impact the HENA has.  The HENA methodology increases the housing need by 560 dpa (i.e. 74%).  This is significant, particularly in the context of Oxford City which has acknowledged its capacity for housing falls far short of its claimed need.   This merits a full and proper explanation within the draft Plan.  
  4. 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.  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 than the projections which have been used.
  5. 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.
  6. We note that as recently as 2018, the objectively assessed need for Oxford City was 93 dwellings per annum, with any figure above this being a ‘policy choice’ (Oxford City – Objectively Assessed Need Update Oxford City Council Final Report October 2018).  This draft Plan: a) Fails to make clear what has changed so dramatically since 2018 b) Fails to distinguish adequately between ‘need’ and ‘requirement’.

3. Not effective 

  1. In the current Local Plan there were also very high numbers of housing that were approved which was supposed to address the affordability issue – given the problem persists, that has clearly been ineffective so on that basis this new plan must fail the effectiveness test.
  2. The statement of common ground does not reflect effective joint working as matters of contention appear to have been deferred – reference page 4 ‘The City Council has opened discussions with the County Council and adjoining districts about our housing need. The points of acceptance and disagreement vary between each district. A separate Statement of Common Ground or individual Statements will be produced for this matter specifically, setting out clearly the points of agreement and disagreement. ‘
  3. The very significant matter of lack of sewage capacity also appears to have been deferred. Page 36 of the Oct 23 Infrastructure Delivery Plan states ‘ Thames Water have also confirmed that funding is available for the delivery of a major increase in treatment capacity at the Sandford Wastewater Treatment Works (WWTW). ‘ Given the current financial difficulties Thames Water find themselves in it would seem appropriate to test this assertion and actually obtain a PLAN with a delivery date. Their stormwater discharge site https://www.thameswater.co.uk/edm-map, showing Sandford’s ongoing regular discharges of raw sewage into the Thames , states ‘We’re finalising plans for a major upgrade at Oxford STW, costing more than £130m. This will provide a significant increase in treatment capacity, larger storm tanks and a higher quality of treated effluent going to the river. We can’t yet confirm a completion date.’ 

4. Not consistent with national policy.

  1. This submission draft is not consistent with national Levelling Up as it seeks to create further economic activity in the South rather than in areas of the country that desperately need new jobs and where house prices are markedly lower. It is also not consistent with Net Zero 2050 as urbanising more of Oxford (and Oxfordshire) to supercharge growth will result in loss of valuable countryside (currently serving as an effective carbon sink) and create significant carbon emissions from construction, transport infrastructure and increased commuting. 

Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. (Please note that non-compliance with the duty to co-operate is incapable of modification at examination.) It would be helpful if you could suggest revised wording for the policy or text

1.The document should be updated once all duty to cooperate agreements are in place and then be subjected to public scrutiny through another Regulation 19 prior to examination by an Inspector.

2. The housing requirement figure should be derived from the standard method.  All references to the HENA and its arbitrary alternative methodology should be removed. It would be helpful to members of the public to understand the real need for housing based on reasonable projections of organic growth more in line with UK population growth expectations of circa 5%. It should then be made clear the political choices that are being taken to have more growth than this with clear rationale. This baseline figure was purportedly 93 dwellings per annum in 2018. An exceptional circumstance should be included to reduce any housing number to the level that Oxford City has capacity to deliver, given the opposition from the surrounding districts to sharing the expansionist vision that Oxford City and Cherwell District Council have.  

3. Were an approach based on Doughnut Economics and consistent with UK Levelling Up and Net Zero 2050 be taken it is expected that the document would change considerably through the additional insights that would be gained around impacts on the environment and societal wellbeing. This may necessitate a new Regulation 18 process.  

4. A detailed analysis and thorough explanation of why the previous plan has proven to be ineffective at delivering homes in sufficient numbers that key workers can afford. This may then result in different policy options being considered that have not been included. For instance, it would appear that Oxford City are relying on land value uplifts of market housing to help pay for affordable units and also to top up their funds to offset the annual reductions of funding from central government. An alternative might be to have a policy to only build council or social rent homes on land the council owns. It may also be appropriate to ask Oxford University to provide funding from the extraordinary land value uplifts it is currently benefiting from but which do little to help local communities. 

5. It is vital that there is a realistic, funded plan in place by Thames Water to improve the Oxford Sewage Treatment Works at Sandford which cannot currently serve the existing population let alone accommodate the additional waste water and sewage which will be generated by further development in the area.