Inspector's Report
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Report to South Oxfordshire District Council by Jonathan Bore MRTPI an Inspector appointed by the Secretary of State Date: 27 November 2020 Planning and Compulsory Purchase Act 2004 (as amended) Section 20 Report on the Examination of the South Oxfordshire Local Plan 2011-2034 The Plan was submitted for examination on 29 March 2019 The examination hearings were held between 14 July 2020 and 7 August 2020 File Ref: PINS/Q3115/429/6 Contents Abbreviations used in this report 3 Non-Technical Summary 4 Introduction 5 Context of the Plan 6 Public Sector Equality Duty 8 Assessment of Duty to Co-operate 8 Consultation 9 Assessment of Other Aspects of Legal Compliance 9 Assessment of Soundness Issue 1 - Whether the Plan’s housing requirement is soundly based 11 Issue 2 - Whether the Plan’s spatial strategy is appropriate, having regard to the need to accommodate necessary growth, promote sustainable patterns of development and protect the Green Belt 17 Issue 3 - Whether the Plan’s strategic site allocations and its approach towards development in the towns, villages and countryside, is sound 24 Issue 4 - Whether the plan will provide adequately for the delivery of housing to meet the housing requirement, and whether 5 years’ supply of homes can be maintained 43 Issue 5 - Whether the Plan’s policies and provisions are viable and whether its infrastructure policies are sound 45 Issue 6 - Whether the Plan provides appropriately for the housing needs of all parts of the community 48 Issue 7 - Whether the Plan provides appropriately for business, employment, retail, town centre and community needs 53 Issue 8 - Whether the Plan’s policies on design, environmental issues and the control of development are sound 57 Overall Conclusion and Recommendation 65 Schedule of Main Modifications Appendix 2 South Oxfordshire District Council, South Oxfordshire Local Plan 2011-2034, Inspector’s Report 27 November 2020 Abbreviations used in this report AONB Area of Outstanding Natural Beauty dpa Dwellings per annum MM Main modification NPPF National Planning Policy Framework OAN Objectively assessed need SHMA Strategic Housing Market Assessment SSSI Site of Special Scientific Interest 3 South Oxfordshire District Council, South Oxfordshire Local Plan 2011-2034, Inspector’s Report 27 November 2020 Non-Technical Summary This report concludes that the South Oxfordshire Local Plan 2011-2034 provides an appropriate basis for the planning of the District, provided that a number of main modifications (MMs) are made to it. South Oxfordshire District Council has specifically requested that I recommend any main modifications necessary to enable the Plan to be adopted. Following the hearings, the Council prepared schedules of the proposed modifications and carried out sustainability appraisal and habitats regulations assessment of them. The main modifications were subject to public consultation over a six-week period. In some cases, I have amended their detailed wording and added consequential modifications where necessary. I have recommended their inclusion in the Plan after considering the sustainability appraisal and habitats regulations assessment and all the representations made in response to consultation on them. The Main Modifications can be summarised as follows: • A change in the plan’s end date from 2034 to 2035, with consequent changes in the delivery requirements for housing, employment and other forms of development; • A range of modifications throughout the plan to strengthen its contribution to tackling climate change, including a new policy on carbon reduction; • The introduction of a stepped housing trajectory to reflect past and realistic future delivery rates; • The inclusion of development principles for Didcot Garden Town and for Berinsfield Garden Village; • Changes throughout the plan to policies governing density, to ensure that development is sensitive to local circumstances and needs; • A requirement for compensatory improvements to offset the impact of removing land from the Green Belt; • A change to inset an additional area from the Green Belt at Culham Science Centre; • Requirements for biodiversity net gain, high-quality walking and cycling routes and public transport facilities; • Clarification as to where residential development may take place, including entry level housing, rural exception sites, and specialist accommodation for older people, and clarification as to the circumstances under which affordable housing will be sought; • Changes to the policy framework for the Market Towns, to clarify that they may deliver more homes in certain circumstances than the residual requirement; • Changes to employment delivery requirements and the removal of an unnecessary and onerous policy requiring community employment plans; • Provision to recover and recycle external infrastructure funding; • The insertion of urban design principles; • Changes resulting from the introduction of Classes E, F.1 and F.2 of the Use Classes Order, affecting town centre and community uses; • Modifications to bring the plan’s heritage policies into line with the National Planning Policy Framework (NPPF); 4 South Oxfordshire District Council, South Oxfordshire Local Plan 2011-2034, Inspector’s Report 27 November 2020 • A number of other modifications to ensure that the plan is positively prepared, justified, effective and consistent with national policy and contains up-to-date figures. Introduction 1. This report contains my assessment of the South Oxfordshire Local Plan in terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended). It considers first whether the Plan’s preparation has complied with the duty to co-operate. It then considers whether the Plan is compliant with the legal requirements and whether it is sound. The National Planning Policy Framework 2019 (paragraph 35) makes it clear that in order to be sound, a Local Plan should be positively prepared, justified, effective and consistent with national policy. 2. The starting point for the examination is the assumption that the local planning authority has submitted what it considers to be a sound plan. The South Oxfordshire Local Plan 2011-2034, submitted on 29 March 2019, is the basis for my examination. It is the same document that was published for consultation on 7 January 2019. 3. When adopted, the Plan will become the South Oxfordshire Local Plan 2035 and will guide development and infrastructure to that date. MM1 extends the end date of the Plan to 2035 so that it covers a period of about 15 years, to accord with Paragraph 22 of the NPPF. There are consequent changes throughout the Plan. The South Oxfordshire Local Plan 2035 will replace the 2012 Core Strategy (including the “saved” policies of the South Oxfordshire Local Plan 2011). Main Modifications 4. In accordance with section 20(7C) of the 2004 Act, the Council requested that I should recommend any main modifications necessary to rectify matters that make the Plan unsound and thus incapable of being adopted. My report explains why the recommended main modifications are necessary. These are referenced in bold in the report in the form MM1, MM2 etc, and are set out in full in the Appendix. 5. Following the examination hearings, the Council prepared a schedule of proposed main modifications and carried out sustainability appraisal and habitats regulations assessment of them. The schedule was subject to public consultation for six weeks. I have taken account of the consultation responses in coming to my conclusions in this report, and in this light I have made some amendments to the detailed wording of the main modifications and added consequential modifications where these are necessary for consistency or clarity. None of the amendments significantly alters the content of the modifications as published for consultation or undermines the participatory processes, sustainability appraisal and habitats regulations assessment that have been undertaken. Where necessary I have highlighted these amendments in the report. 5 South Oxfordshire District Council, South Oxfordshire Local Plan 2011-2034, Inspector’s Report 27 November 2020 Policies Map 6. The Council must maintain an adopted policies map which illustrates geographically the application of the policies in the adopted development plan. When submitting a local plan for examination, the Council is required to provide a submission policies map showing the changes to the adopted policies map that would result from the proposals in the submitted local plan. In this case, the submission policies map comprises the set of plans identified as Documents CSD02 and CSD02.1, together with the Strategic Allocation Maps, the Site Allocations, the Green Belt Proposed Changes, the South Oxfordshire District Council Safeguarding Maps, and Town Centre Boundaries and Primary Shopping Frontages which are set out in Appendices 2, 3, 4, 5 and 13 of the Plan respectively. 7. The policies map is not defined in statute as a development plan document, so I do not have the power to recommend main modifications to it. However, certain of the published main modifications to the Plan’s policies require corresponding changes to the policies map and there are some instances where the geographic illustration of policies on the policies map is not justified and changes to the policies map are needed to ensure that the relevant policies are effective. 8. These further changes to the policies map were published for consultation alongside the main modifications in the document entitled “Schedule