I sent an individual response to Oxford City’s Local Plan 2036 (the Vale Liberal Democrat group submitted one as well). By doing this we have declared our interest in being invited to participate in the Examination in Public to come later in the year.
Here is what I said:
Pre-submission response 28 Dec 2018 , Debby Hallett resident of Botley, Vale of White Horse, Debby.Hallett@gmail.com
- Duty to cooperate
With Oxford City at or near full employment, housing at a price that’s unaffordable to almost anyone who wants to live there, and roads congested beyond capacity, it’s not demonstrating cooperation with neighbouring authorities when there are so many employments sites in the plan while at the same time not enough houses to meet City’s Objectively Assessed Need. I live in one of the neighbouring districts, Vale of White Horse, which is expected to provide some of the thousands of homes to meet Oxford’s unmet need. By not doing more to meet its own needs, Oxford increases the burden on neighbouring districts and also increases the traffic congestion on the arterial routes around Oxford. I am somewhat mollified to read that this opinion is also help by some respondents who are from Oxford City itself, so it’s not solely a view taken by neighbours.
Government has set up a scheme that rewards an authority for building more employment sites (business rates retention). Government previously rewarded authorities for building more homes (new homes bonus) but this funding stream for local government ends next year. Assessment is needed to ensure no authority is taking unfair advantage of its neighbours under Duty to Cooperate by building more employment sites at a level that prevents them from providing enough housing. I think this is what Oxford City is trying to do.
Cycle routes providing safe access to Oxford employment sites should be planned for under Duty to Cooperate. Current cycle and car traffic along roads and cycle paths in neighbouring districts leading to work sites in Oxford are above capacity and unsafe. Bus services between neighbouring housing and employment sites, and city sites dwindle each year. There used to be more cross-boundary strategic planning but the regional planning roles have been eliminated. Is this requirement intended to replace what used to be regional collaboration on strategic issues affecting neighbouring authorities? This approach is unsustainable.
- Positively prepared, justified, effective, consistent with national policy
Housing need is based on an out of date evidence base; Government is adopting a new calculation for objectively assessed need that’s based on more up to date evidence. Oxford’s plan must not be based on old, invalid evidence. That isn’t a positively prepared plan.
Oxford should build fewer employment sites and use the sites for housing instead, at an appropriate density for city living. Oxford should change its focus away from creating more housing need (which happens when more employment sites are created), to meeting a housing need growing with each passing year.
Oxford also should have a plan for increasing the rate at which it builds new housing. Recent years numbers have seen the City fall behind in its building pace, with no apparent consequences or efforts to increase the pace.
In spite of asserting that housing is its top priority, Oxford’s plan is written with employment growth as its top priority, leaving an unacceptable burden on its neighbours and ignoring the need for sustainable transport corridors for people to get to and from work.
I would submit that the case for exceptional circumstances to support removing any land from the Green Belt is not made. The guidance on Green Belt law is clear that housing need is not enough of a reason to allow development in the Green Belt.