The Begbroke & Yarnton Green Belt (BYG) campaign has submitted the following response to the Oxford Local Plan 2036 Preferred Options Consultation, August, 2017. The response draws on the helpful response submitted and published by CPRE Oxfordshire.
"BYG wish to raise a number of serious concerns about Oxford City Council’s proposed plans. The City Council’s single-minded pursuit of growth and expansion threatens adverse consequences for its own residents, and devastating effects for surrounding villages.
There is, in the first place, much doubt as to the figures on which Oxford City Council’s plans are based, and which give rise to its assertion of “unmet housing needs”. Speculative assumptions about future population and employment figures result in an exaggerated prediction of housing needs, which Oxford declares it will be unable to meet. Consequently, the City has put pressure on surrounding Councils to undertake massive and damaging development, which would distort and overwhelm their own Local Plans. Circumstances have already changed since the publication of figures derived from the Strategic Housing Market Assessment published in 2014 (e.g. Brexit; shifting patterns in the student population; doubts as to whether employment opportunities will, or should, be focussed within Oxford City). The numbers should be reviewed and revised before they are acted upon.
With or without a more realistic assessment of future housing needs, however, Oxford City Council has not seriously assessed its capacity to meet its own requirements. This capacity would be greatly enhanced by the adoption of creative strategies, such as suggested here.
1. Prioritise housing over new business parks and commercial ventures.
Oxford City Council claim that housing is their highest priority and most pressing need, yet do not demonstrate this in their plans. The Housing and Economic Land Availability Assessment (‘HELAA’) lists 164 hectares of employment land. As the Campaign for the Protection of Rural England (‘CPRE’) observe, this, if developed appropriately for housing instead, could accommodate more than 12,000 new houses. This would require a modest increase in the required level of housing density, but, without threat to Oxford’s architectural heritage, could lead to attractive and affordable new communities within the city boundaries. Such development would allow Oxford City Council to meet its housing needs, without encroaching on neighbouring districts or the Oxford Green Belt. Further land used for employment, on the other hand, only exacerbates the housing crisis.
The pressing need for housing is for people already resident in the City, and indeed for those without homes at all. It is a matter of urgency to provide affordable homes for key workers, near their places of employment. This would be beneficial in itself, and would also prevent further, unsustainable increases in traffic. Exporting the demand for housing to surrounding districts does not address the need for local housing where people actually work. It does not provide affordable homes where they are needed and exacerbates existing traffic problems. It also threatens irreversible damage to nearby rural districts and the Oxford Green Belt.
2. The use of brownfield sites.
One of the requirements set out in the National Planning Policy Framework (“NPPF”) is that Local Authorities must demonstrate, before using any Green Belt land, that they have adequately assessed the potential capacity of brownfield sites within their area. Although 20 hectares of brownfield land are identified in the plan, they, like other areas of under-used land, are listed only as “for further investigation”. Once again, if used effectively, such land would remove the need for the Oxford City Council to encroach on the Oxford Green Belt within its own boundaries, or to expect neighbouring district councils to be deleting land from the Oxford Green Belt either.
Further housing capacity could also be provided by the use of currently unoccupied buildings, and of the plots of land that stand idle, awaiting more lucrative development opportunities. Existing business parks (e.g. The Oxford Science Park and The Oxford Business Park) are under-used, and adjoining land could also be used for housing. Furthermore, 75 hectares of surplus public sector land are identified within the plan as “recommended for further investigation”. Use of such land, alone, would yield a greater capacity for housing than would be possible from all the Green Belt areas proposed for use within the City. (CPRE).
The most urgent consideration in relation to current proposals is, furthermore, the need to protect the Oxford Green Belt. This land preserves Oxford as a compact city, with clear boundaries, affording access to the countryside to all its residents. It mitigates against pollution, both of air and light, and is an essential element of Oxford’s character. Above all, it prevents the urban sprawl that would result from any incursion into it, which would be irreversibly damaging to the City itself and, also, devastatingly, to all its surrounding villages.
Surveys show that the great majority of residents, within and outside the Oxford City, highly value the Green Belt and wish it to be preserved. This is in accord with the NPPF, which defines Green Belt as a permanent designation. No “exceptional circumstances” have been demonstrated by Oxford City Council which might be said to justify breaching it. Reasonable alternatives to incursions into the Green Belt do exist and must be pursued.
In summary, we urge the Oxford City Council to:
Review the inflated figures on which current plans are based.
Withdraw its exaggerated demand for inappropriate housing development in neighbouring district councils.
Delete all Green Belt sites from the plan, and expect adjoining district councils to do the same.
Review and properly assess the many reasonable alternative sites that could sustain appropriate and balanced development within Oxford.
Prioritise maintenance of the quality of life in Oxford and its surrounding districts over the relentless pursuit of profit and endless commercial expansion."
Executive Committee, Begbroke and Yarnton Green Belt Campaign