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, 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.

Cherwell Local Plan 2040 – have your say by 3 Nov

The Cherwell Local Plan 2040 is out for consultation until this<strong> Friday 3 November</strong>.

See: <a id=”LPlnk950354″ class=”x_OWAAutoLink” href=”″ target=”_blank” rel=”noopener noreferrer”></a>

If you just have a few minutes, see the main part of NNGO’s response, where there are some clear bullet points that you could copy, put into your own words and send to:


In brief:
<li>The projected growth figures are still wildly exaggerated.</li>
<li>The housing figures are not based on the Government’s standard housing methodology.</li>
<li>There is no justification for Cherwell to accept Oxford’s inflated overspill. This would be better accommodated by making more efficient use of land within the City’s boundaries, including prioritising city centre sites for housing rather than employment.</li>
<li>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.</li>
Please make your views known.

Cherwell LP 2040 Review Consultation NNGO Oct 2023 FINAL

Don’t let Oxford City dictate our county’s future

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


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.

  1. 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.

  1. 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%.

  1. 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.

  1. 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.

  1. 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
  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

Template letter to Councillors

Template letter to Cherwell Councillors

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

An Opportunity to Scrap 5 Year Housing Supply Rules

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:

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