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”. 

———————————————————————————————————————————————————————-

 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.