Housing for Particular Groups Oxford Brookes University Written Statement

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement

November 2019

Word Count: 3,000 2 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Contents

1. Introduction 4

2. Lack of Consultation 5

3. The Principle of restricting the refurbishment, redevelopment or expansion of academic floorspace at Oxford Brookes University in respect of the supply of purpose-built student accommodation 6

4. Purpose Built Student Accommodation: The proposed Local Plan and constraints on supply 9

Appendices 10

A. OCC/OBU Consultation timeline B. Clive Booth Student Village 18/02587/FUL decision notice C. Headington Area Land Use Map D. Estimated and Projected number of 18-year olds in the UK E. Plan of Oxford Brookes University’s Estate F. The Sinclair Building decision notice G. Assumptions behind the University’s Accommodation Trajectory H. The Oxford Brookes University Trajectory I. Oxford Mail Article 7th June 2019 J. The Inspector’s Report in to the 2013 Sites and Housing DPD K. Policy HP6, Sites and Housing DPD

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 3 1. Introduction

1.1 The proposed Plan is unsound in its current form as it meets none of the four tests of soundness, which has been exacerbated by a lack of effective consultation with Oxford Brookes University.

1.2 The operation of policy E2 has been rendered unsound owing to proposed modifications and its relationship to SP18 is unclear.

1.3 The proposed student cap does not reflect the actual supply of student accommodation in the years ahead. There is no evidence the cap in Policy H9 can be achieved. It is therefore regressive and will restrict the investment the University needs to make in its estate in the years ahead.

1.4 Moreover, Policies H2 and H8 will inhibit the future supply of new student accommodation, compounding these issues further.

4 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 2. Lack of Consultation

2.1 The absence of effective consultation by Oxford 2.4 The Plan also fails to comply with paragraph 4 of City Council (OCC) with OBU is contrary to National the Housing needs of different groups Advice states: Policy and inconsistent with the council’s Statement ‘Local Planning Authorities will also need to engage of Community Involvement (SCI). We set out an with universities…to ensure they understand their audit of consultation with OBU in Appendix A. student accommodation requirements in their area.’ Notwithstanding engagement at the earlier stages of the draft Plan, OCC failed to engage with OBU at the 2.5 In the absence of consultation with OBU as a local critical juncture when it was formulating its detailed organisation and business, OCC has failed on this policy and resisted requests for meetings. aspect of plan-making. The proposed policies insofar as they relate to the University cannot be 2.2 OBU is a stakeholder as defined by paragraph 1.1 considered sound given that they go to the heart of of the SCI. It would have expected ‘Participation’ the successful operation of OBU. under paragraph 3.4. Whilst OBU was asked for its views, they were not taken on board as the e-mail 2.6 We were granted a meeting with OCC in March 2019, exchanges attest. 6 months after we provided detailed comments and just as the Plan was being submitted for 2.3 The Plan is therefore not compliant with NPPF Examination. We committed to working towards Paragraph 16 c) which requires plans to ‘be shaped a Statement of Common Ground (SoCG) and this by early, proportionate and effective engagement work has commenced. We are pleased to note that between planmakers and communities, local OCC has formally stated in its first draft SoCG dated organisations, businesses, infrastructure providers and 18th October 2019 that is willing to reconsider the operators and statutory consultees.’ threshold of the student cap. The majority of this statement will address this point.

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 5 3. The Principle of restricting the refurbishment, redevelopment or expansion of academic floorspace at Oxford Brookes University in respect of the supply of purpose-built student accommodation

3.1 The Plan is both ineffective and unjustified in its basis; OCC has not been proactive, positive and approach to OBU’s ability to develop new and collaborative in proposing this policy. Its inclusion existing floorspace and is not compliant with the is contrary to the positive support for educational approach which LPAs should apply to educational uses afforded in NPPF Policy 94. For OBU specifically, uses and institutions. the policy is not compliant with ECO.3 (Industrial Strategy) and ECO.4 (Oxfordshire Strategic Economic Plan) which are dependent on flexibility and Policy E2 – Teaching and research continual improvement within the Higher Education sector. 3.2 The Plan has not been positively prepared and does not comply with national policy. It under-estimates the positive economic and social contribution that Policy SP18 – Headington Hill Hall OBU makes to the city at a number of points. and Clive Booth Student Village

3.3 Paragraph 2.11 of the Plan ignores the contribution 3.7 Policy SP18 is unsound in that its operation and OBU makes to the city’s economy in failing to list the interaction with Policy E2 in respect of other. Parts economic benefits it brings; namely the training of of the University’s estate is not clear. The policy a local workforce and provision of a steady stream is ineffective in that it could lead to development of graduates for the workforce. Paragraph 2.11 is management decisions which restrict the capacity for written from the perspective of the University of significant change to the SP18 area, permitting only Oxford only and reinforces the lack of understanding minor changes outside of that designated area. The OCC has in respect of OBU’s position resultant from distinction between Policy E2 and SP18 is not clear. an absence of effective engagement. A revised Policy SP18 in accordance with our earlier representations is needed to provide OBU with clarity 3.4 Paragraph 2.15 stages ‘both institutions have regarding investment in its wider estate. We see no indicated that they have the potential to deliver more impediment to this proposal given that the campus of their own needs through redevelopment’. In actual sites firmly within an area dominated by institutional fact, OBU has been clear that it cannot meet its need uses, as demonstrated in the enclosed land use plan and the recent refusal of planning permission for (Appendix C). the redevelopment of Clive Booth Student Village (18/02587/FUL – Appendix B) underlines this point. Policy H9 – Linking the delivery of new/ 3.5 However, OBU supports the expression of the policy insofar as it is linked to Policies H8 and H9 in that it redeveloped and refurbished university is targeting ‘unchecked growth in student numbers’ academic facilities to the delivery of university as opposed to moving existing students out of HMOs provided residential accommodation which is an entirely different, and unjustified and clearly ineffective strategy (see below). 3.8 To date, OCC’s policies related to controlling HMOs in respect of OBU have been consistently ineffective: 3.6 Finally, the proposed four tests introduced by OCC do not meet the test of planning positively. A • Oxford Local Plan 2001-2016: OBU restricted to University should not have to justify the principle of 3,500 students in HMOs up to 2008 and 3,000 investment in Higher Education and this is our key thereafter; point as it runs counter to the support previously articulated by E2. We can go further and say there • Oxford Core Strategy 2026: OBU restricted to 3,000 is a risk that new development may not comply students in HMOs; with all the tests as the expectation is for all new developments to be both global and local in their • Draft Oxford Local Plan 2036: OBU restricted to function, which will be contradictory at times. 3,500 students in HMOs until 1st April 2022 and The policy test as proposed is unjustified on this 3,000 thereafter.

6 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 3.9 OBU only achieved the target once, in 2012 when tuition fees were introduced, and many students deferred entry. The numbers have quickly recovered as the following graph from the 2018 Annual Monitoring Report shows:

Oxford Brookes Number of students living outside university provided accomodation 2010/11 – 2017/18

4500 4180 4089 4000 3611 3747 3381 3451 3500 3072 2836 3000

2500

2000

1500

1000

500

0 2010/11 2011/12 2012/13 2014/15 2014/15 2015/16 2016/17 2017/18

3.10 Setting aside the impact of tuition fees, the on- 3.14 These increases in those seeking accommodation campus population within Oxford has in fact been within Oxford have occurred despite the fact that broadly steady. In 2010, the University had 17,876 student numbers have declined slightly and despite students. A substantial portion of these students the fact that OBU will be shrinking its estate from were not physically present in Oxford in that they 125,000m2 to a proposed 100,000m2, arising from were affiliated to Colleges or studying elsewhere such the disposal of the Wheatley campus. A map of OBU’s as at the Swindon campus. There were also students estate is provided in Appendix E. affiliated to Colleges abroad. Of the 17,876, circa 12,470 were in Oxford. 3.15 This analysis demonstrates that there has been no ‘unchecked growth’ in student numbers against 3.11 Over the decade, the overall size of the institution has a backdrop of a University shrinking its estate reduced to 16,579 whilst the Oxford based population whilst increasing PBSA. The current policy is clearly has also reduced slightly to 12,038. This is partly ineffective in trying to transfer existing HMOs because of the student recruitment cap (removed in into general market housing when ignoring three 2015) but also the demographic dip in the number fundamental points: of 18-year olds entering higher education. This dip started in the late 2000s, but is now about to grow i. The overall supply of general market housing within again as the graph in Appendix D shows. the Strategic Housing Market Area has increased since the introduction of this policy in 2001 and is set 3.12 With rising demographic trends, the University to increase substantially again owing to the work of intends to hold its numbers and stay within the range the Oxfordshire Growth Board. The student cap has established over the last decade i.e. circa 12,500 never increased in two decades despite increasing students in Oxford over the next 5 years, partly general market housing and evidence that OCC’s because the Oxford estate is at or nearing capacity policies were failing to deliver for OBU; with planned relocations from Wheatley. Most of the growth in the 2020s will come from outside Oxford at ii. The University is seeking to make its own contribution affiliated Colleges or overseas so are not relevant to to housing need by converting its Wheatley campus this debate. into a draft allocation for up to 500 homes which would equate to 1,250 student bedspaces; 3.13 However, the on-campus population has seen a reduction in students living at home or outside the iii. Students are location specific and need city and an increase in those who want to live in accommodation in close proximity to the campus student accommodation of all types. and learning locations such as the hospitals.

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 7 3.16 The current policy ineffectively and unjustifiably seeks 3.24 Our trajectory highlights three problems with the a retrospective remedy to student housing in Oxford, as Council’s assumptions: opposed to aligning with realities and managing future impacts, to plan effectively for student housing in Oxford. i. OCC’s preferred policy position between 2022 and 2036 cannot be delivered even if all identified 3.17 Indeed, OCC is now seeking to restrict all capital schemes are delivered and OBU underwrites all investment in the estate to force a reduction by restricting nomination agreements with third party providers, a the refurbishment, redevelopment or expansion of guarantee it cannot provide or deliver; academic floorspace that could technically support the expansion of student numbers. ii. When a more realistic approach is taken to delivery (i.e. the mid-point), OCC has not identified a viable 3.18 We refer to the recent application for the refurbishment site in excess of 1,000 bedspaces that can close the of the Sinclair Building (17/02631/FUL – Appendix F). As an gap within the first 5 years of the Plan and there is no application that proposed a rationalisation of the existing confidence that Policy H9 will be of relevance beyond building, it added 10m2 to the overall floorspace. Condition 2026; 5 restricted occupation until it could be demonstrated that OBU could comply with the cap. We are not convinced iii. In any event, we are not convinced that an unending the condition is compliant with the six tests1. Against supply of PBSA will move students from HMOs - a the backdrop of a shrinking estate and steady student view shared by the Planning Committee which numbers, it is difficult to see how application of the policy refused permission for the Clive Booth Student could be enforced. Village redevelopment in June 2019 (Appendix I - though in that case, the on-campus nature of the 3.19 Policy H9 is therefore both negative and draconian as well accommodation and the fact it is a direct University as ineffective: it prevents OBU from investing in its estate let would absorb capacity from HMOs. However, the without securing the Policy’s stated objective. Indeed, OCC reasoning of the Committee is correct to a certain is unable to demonstrate that the delivery of its policy can extent in that it cannot be certain that halls located be effective against a backdrop of stable student numbers within existing student residential areas will always and a smaller estate. fill in priority to HMOs. HMOs will always offer an important first step in independent living that many 3.20 The University has not had sight of OCC’s calculations in students prefer irrespective of the availability of support of how they think OBU could meet the cap over PBSA). time, to determine how it is confident that the current stepped limits from 3,500 to 3,000 students in HMOs are 3.25 We would respectfully ask the Inspector to adjust Policy viable. In response, the University has reviewed its estate, H9 so that it directly correlates to Policy E2 and links the all nomination agreements with third party providers and expansion of student accommodation to any expansion likely student growth to ascertain how many students are in student numbers which would increase students likely to continue to rely on HMOs by 2026. living within HMOs above 4,000. This figure aligns itself 3.21 In modelling that trajectory, we have assumed a best with the trajectory and ensures the Plan will be sound case and a worst case scenario as it is not possible to and deliverable within the first 5 years and can endure predict entirely what will happen over the next 5 years, beyond that. but assuming a mid-point between these scenarios seems reasonable and consistent with similar exercises 3.26 Critically, this approach will ensure that OBU is capable undertaken in calculating the city’s OAN. of investing in its estate to ensure its teaching and learning environments remain competitive with others 3.22 Our assumptions are set out in Appendix G and the in the UK Higher Education Sector, which have no Trajectory is reproduced in Appendix H. comparable restriction. This will align Policy H9 with paragraph 94 of the NPPF and crucially, paragraph 4 of 3.23 These assumptions suggest a loss of bedspaces on the one the Housing Needs of Different Groups Advice, which hand, or an increase on the other, with the mid-point being states that: roughly at current levels, despite the loss of Wheatley, time expired accommodation at Harcourt and the exiting of ‘Strategic policy-making authorities are encouraged to head lease accommodation. consider options which would support both the needs of the student population as well as local residents before imposing caps or restrictions on students living outside Revised Policy H9 scenario - Numbers of Oxford university-provided accommodation.’ Brookes University students in HMOs by 2026: Best case Scenario: 3,671 3.27 The preceding analysis demonstrates that the Council Worst case Scenario: 4,329 has discounted the needs of the student population in Mid-point between Scenarios: 4,000 students in HMOs by 2026 formulating its proposed cap.

8 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 4. Purpose Built Student Accommodation: The proposed Local Plan and constraints on supply

4.1 Having clearly established that OCC is adrift from its the application of an affordable housing levy is not target by circa 1,000 bedspaces and has not planned appropriate on those sites which are not in competition for the needs of the student population, we now turn to with general housing or appropriate in instances where the likelihood of new or existing sites coming forward in the Universities would be starved of potential sites. light of Policies H8 and H2 which will influence supply: 4.8 The qualifications and exemptions set out in Policy HP6 (Appendix K) should be reinstated, namely: H8 – Provision of new student accommodation • Existing campus sites as of the date the draft Plan 4.2 Our representations have already made the point that was submitted the withdrawal of those sites situated along designated • Allocated sites Main Thoroughfares, reinforces the ineffectiveness • Any scheme which will assist in reducing of Policy H9. Main Thoroughfares are designated in accommodation below the cap set out in H9; Appendix 3 of the Sites and Housing DPD. • Those proposals for the intensification or expansion of an existing student accommodation site. 4.3 In light of the evidence we have provided regarding the availability of student accommodation over the next 4.9 The Inspectors should be aware that the proposed Clive 5 years, there is no evidence to support the Council’s Booth Student Village scheme, had it been approved, position that viable and sustainable locations for would not have come forward for development if an 2 student accommodation should be restricted further, affordable housing levy of £2,996,550.2 was applied particularly as there are existing facilities that are across the net additional floorspace, in addition to the CIL 3 functioning well but would have been refused had they contribution of £2,140,393 . been assessed against this policy. 4.10 It is not in the interests of positive planning to rely on 4.4 Finally, the last clause within Policy H8 is problematic viability appraisals as a means to achieve delivery on to OBU: the refusal of planning applications seeking a sites that will not become available for general housing, reduction in bedspaces. It is not uncommon for older particularly as this Plan, along with those of neighbouring accommodation schemes to be refurbished, with a net authorities will deliver more affordable housing through reduction in bedspaces arising from the application of its general housing policies than under the previous Sites modern expectations and requirements. Rooms can be and Housing DPD. enlarged and converted in to social/study spaces and other supporting functions. These changes are essential 4.11 Moreover, the argument advanced by the Council that in order to provide a modern student experience as well additional student accommodation generates more lower as deliver spaces essential for better pastoral care. The paid jobs amongst those who need access to affordable Policy conflicts with the needs of OBU’s students and by housing is speculative and unjustified. The number of jobs extension, the interests of the University. generated by a typical PBSA scheme is very limited and far less than similar jobs generated by say, the retail or 4.5 The policy is clearly unjustified and does not plan hospitality sectors, which are not asked to make a similar effectively for the needs of students. contribution.

4.12 In not planning effectively for student accommodation, OCC should not be allowed to restrict supply further Policy H2 – Delivering affordable homes with its inequitable, regressive and unjustified policy, particularly as these charges are simply passed on to 4.6 Part b) of Policy H2 which requires a financial students who are a vulnerable segment of the housing contribution is unjustified. market in terms of the proportion of their resources which is spent on rent. 4.7 A similar initiative was proposed in the draft Sites

and Housing Development Plan Document and this Notes was contested at the subsequent examination in 1 necessary; relevant to planning; relevant to the development to be permitted; enforceable; precise; and reasonable in all other respects. 2012. Relevant extracts from the Inspector’s Report 2 Affordable Housing Contribution Policy H2, b) £140 (rate) x 21,403.93m2 (CBSV chargeable area) = £2,996,550.20 (dated 2nd January 2013) are provided in Appendix 3 Rate of CIL = 21,403.93m2 (CBSV chargeable area) * £144..19 (2019 Index Figure) / £100 (2013 Index Figure) = £14,844.25 x £144.19 J, particularly paragraph 46 which concluded that = £2,140,393

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 9 Appendices

A. OCC/OBU Consultation timeline

B. Clive Booth Student Village 18/02587/FUL decision notice

C. Headington Area Land Use Map

D. Estimated and Projected number of 18-year olds in the UK

E. Plan of Oxford Brookes University’s Estate

F. The Sinclair Building decision notice

G. Assumptions behind the University’s Accommodation Trajectory

H. The Oxford Brookes University Trajectory

I. Oxford Mail Article 7th June 2019

J. The Inspector’s Report in to the 2013 Sites and Housing DPD

K. Policy HP6, Sites and Housing DPD

10 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Appendix A – Oxford City Council and Oxford Brookes University Consultation

5th August 2016 OBU submitted Questionnaire to First Steps Consultation

February 2017 OBU emailed the Planning Policy Team at OCC with info on the academic level of students

29th August 2017 OBU submitted detailed rep to Preferred Options (Reg. 18) Consultation

22nd November 2017 OBU responded to OCC’s request for information on the HELAA

Feb 2018 Leader and Chief Exec of City Council met the vice chancellor of OBU

9th April 2018 Leader and Chief Exec of City Council met the vice chancellor of OBU

15th May 2018 Planning Policy Manager met with OBU to discuss Wheatley, student numbers and new PBSA plans

15th August 2018 OBU asked to informally comment on the draft of policies H8 and H9

4th September 2018 OBU responded to that informal request, saying it had serious misgivings about the Policies and requested a meeting

17th September 2018 OBU advised by OCC that their response was too late and that the policies had been subsequently taken through to the Council’s Committee cycle. We were directed to make our views known through the statutory process

27th December 2018 OBU submitted detailed rep to draft Submission Local Plan

19th February 2019 OCC asked OBU for a meeting to discuss their rep to the draft Submission Plan;

18th March 2019 that meeting took place, but the discussion too late and the draft plan was submitted in that same month. The subjects discussed related to mooted increases in CIL and work towards a SoCG

17th April 2019 E-mail of 18th March acknowledged and Planning Committee date for Clive Booth Student Village application fixed for 5th June

29th May 2019 Inspectors’ write to OCC regarding the submitted plan’s effectiveness, requesting details of their engagement with OBU

5th June 2019 Clive Booth Student Village application refused at Committee

July 2019 OCC respond to Inspectors’ question 4, setting out their consultation with OBU

19th July 2019 Inspectors’ responded to OCC’s response, stating that ‘these matters will be discussed at the examination hearings and we will be seeking statements from hearing participants in due course.’

10th September 2019 OBU wrote extensively to the Inspectors to correct numerical factual inaccuracies in the Council’s account regarding the consultation process as detailed in their response to Q4 in the first round of questions posed by the Inspector.

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 11 Appendix B – Clive Booth Student Village 18/02587/FUL Decision Notice

Planning Services St Aldate’s Chambers 109 – 113 St Aldate’s Oxford OX1 1DS

Central Number 01865 249811

On Behalf of: Oxford Brookes University C/o Miss Susannah Byrne Turnberry Planning Ltd 41-43 Maddox Street London W1S 2PD

APPLICATION FOR PLANNING PERMISSION Town and Country Planning Act 1990

DECISION DATE: 21st June 2019

PROPOSAL: Proposed demolition of Blocks C, F, G, H, J, K, L and M of the Clive Booth Student Village and erection of 1,077 student bedrooms with associated communal and social facilities (reference 18/02587/FUL) (revised land ownership certificate) (Amended Plans)

AT: Site Of Blocks C F G H J K L And M Clive Booth Hall John Garne Way

NOTICE OF REFUSAL OF PLANNING PERMISSION 18/02587/FUL

Following consideration of the application in respect of the proposal outlined above it was resolved to REFUSE PLANNING PERMISSION for the following reasons:-

REASONS :

1 The proposed development by reason of its siting, scale, density, and height would appear as a strident and consequently intrusive and incongruous intervention on the prominent wooded hillside that makes a significant contribution to the character and appearance of the Headington Hill Conservation Area, and the setting of Central Conservation Area, resulting in harm to the character and appearance of the area and the significance of these designated heritage assets. It would also have an adverse impact on the setting of the John Garne Way allotments and views from the allotments back towards the wooded hillside that makes an important contribution to the character and appearance of the Headington Hill Conservation Area. Moreover the resultant harm has not been sufficiently mitigated by a careful design or adequately justified. The identified public benefits would not outweigh the less than substantial harm to designated heritage assets that would arise from the development contrary to paragraph 196 of the NPPF. The proposal therefore fails to comply with the governments planning policies in the NPPF, the policies CP1, CP6, CP8, HE7 of the Oxford Local Plan, policy CS18 of the Oxford Core Strategy, Policy HP9 of the Sites and Housing

www.oxford.gov.uk

12 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Plan and policies CIP1, CIP2, CIP3 and GSP4 of the Headington Neighbourhood Plan, and therefore fails to discharge the statutory duty set out within Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990

2 The proposed development by reason of its size, scale, and siting would result in the loss of significant trees within the site that contribute to its distinctive sylvan character and position within the Eastern Hills. Further, the proposed mitigation planting would fail to offset the loss of these trees in the short to medium term. Consequently the development would have a significant adverse impact upon public amenity of the site and its setting within the hillside contrary to policies NE15 and NE16 of the Oxford Local Plan

3 That having regards to the reasons listed above, the public benefits of the proposal, in particular the releasing of houses back to the private rental market would not be sufficient to outweigh the less than substantial harm caused by this development to the local area including to the significance of a number of designated heritage assets, and therefore would not meet the test set out in paragraph 196 of the NPPF, or constitute sufficient material considerations that would outweigh policies CP1, CP6, CP8, HE7, NE15, and NE16 of the Oxford Local Plan, policy CS18 of the Oxford Core Strategy, Policy HP9 of the Sites and Housing Plan, and policies CIP1, CIP2, CIP3 and GSP4 of the Headington Neighbourhood Plan.

INFORMATIVES :-

1 In accordance with guidance set out in the National Planning Policy Framework, the Council tries to work positively and proactively with applicants towards achieving sustainable development that accords with the Development Plan and national planning policy objectives. This includes the offer of pre-application advice and, where reasonable and appropriate, the opportunity to submit amended proposals as well as time for constructive discussions during the course of the determination of an application. However, development that is not sustainable and that fails to accord with the requirements of the Development Plan and/or relevant national policy guidance will normally be refused. The Council expects applicants and their agents to adopt a similarly proactive approach in pursuit of sustainable development.

2 The local planning authority has taken into account the contents of an accompanying Environmental Statement submitted under the provisions of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 in determining the planning application.

3 This application was refused by Committee contrary to officer recommendation.

Adrian Arnold Acting Head of Planning Services Please quote reference number 18/02587/FUL in all communications

IT IS IMPORTANT THAT YOU SHOULD READ THE NOTES ACCOMPANYING THIS NOTICE

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 13 GUIDANCE NOTES FOR APPLICANTS WHERE AN APPLICATION HAS BEEN REFUSED

You are reminded that you can submit another similar application for development without needing to pay a fee provided it is submitted by the same applicant on the same site and within 12 months of the date of registration of the original application.

The Council offers pre-application advice for which there are separate fees for householder, listed buildings and other types of application. You can see further information on pre-application advice and download the necessary form to apply for this at www.oxford.gov.uk/PageRender/decP/Pre-Application_Advice_occw.htm

1. PLANNING APPLICATIONS AND APPLICATIONS FOR LISTED BUILDING CONSENT AND CONSERVATION AREA CONSENT.

1. If the applicant is aggrieved by the decision of the Local Planning Authority to refuse permission, he or she may appeal to the Secretary of State for the Environment under Section 78 of the Town and Country Planning Act 1990 (or Section 20 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 8 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990 in respect of listed buildings in conservation areas), within six months of the date of this notice. If the refusal is against a Householder application, received after 5th April 2009, the appeal must be lodged within 12 weeks of this notice. (Appeals must be made on a form which is obtainable from the The Planning Inspectorate, Customer Support Unit, Room 3/15 Eagle Wing, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6PN (Tel. 0117 372 6372) www.planning-inspectorate.gov.uk). The Secretary of State has power to allow a longer period for the giving of notice of appeal but will not normally be prepared to exercise this power unless there are special circumstances which excuse the delay in giving notice of appeal. The Secretary of State is not required to entertain an appeal if it appears that permission for the proposed development could not have been granted by the Local Planning Authority having regard to the statutory requirements, to the provision of the development order, and to any directions given under the order. The Secretary of State does not in practice refuse to entertain appeals solely because the decision of the Local Planning Authority was based on a direction given by her or him.

2. If permission is refused by the Local Planning Authority or by the Secretary of State for the Environment and the owner of the land claims that the land has become incapable of reasonably beneficial use in its existing state and cannot be rendered capable of reasonably beneficial use by the carrying out of any development which has been or would be permitted, he or she may serve on the Oxford City Council a purchase notice requiring the Council to purchase her or his interest in the land under Section 137 of the Town and Country Planning Act 1990 or Section 32 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 9 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990 in respect of listed buildings and buildings in conservation areas.

3. In certain circumstances, a claim may be made against the Local Planning Authority for compensation, where permission is refused or granted subject to conditions by the Secretary of State on appeal or on a reference of the application to her or him. The circumstances in which such compensation is payable are set out in Section 114 and Part II of Schedule 3 of the Town and Country Planning Act 1990 (or Section 27 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 9 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990 in respect of listed buildings).

2. APPLICATION FOR CONSENT TO DISPLAY ADVERTISEMENTS

If the applicant is aggrieved by the decision of the Local Planning Authority to refuse consent, he or she may appeal to the Secretary of State for the Environment in accordance with Regulation 17 and Part 3 of Schedule 4 of the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 within eight weeks of the receipt of this notice. (Appeals must be made of a form which obtainable from The Planning Inspectorate, Customer Support Unit, Room 3/15 Eagle Wing, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6PN (Tel. 0303 444 5000) www.planning-inspectorate.gov.uk).

14 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Appendix C – Headington Area Land Use Map

Institutional

Residential

Greenspace

Area of Change (Policy SP18)

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 15 AppendixAppendix C – Being D – 18 Being in 2018 18 (Office in 2018 for National(Office Statistics) for National Statistics) Appendix C – Being 18 in 2018 (Office for National Statistics)

Appendix C – Being 18 in 2018 (Office for National Statistics) Estimated and projected number of 18-year-olds in the UK population, 2000 to 2034

https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/articles/being18in2018/2018-09-13 https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populat ionp rojections/articles/being18in2018/2018https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populathttps://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populat-09-13 ionp ionp rojections/articles/being18in2018/2018 rojections/articles/being18in2018/2018-09-13-09 -13

16 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019

12 12

Appendix E – Plan of Oxford Brookes University’s Estate

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 17 Appendix F – Sinclair Building (17/02631/FUL) Decision Notice

Planning, Sustainable Development St Aldate’s Chambers and Regulatory Services 109 – 113 St Aldate’s Oxford OX1 1DS

Central Number 01865 249811

On Behalf of: Mrs Sue Holmes C/o Mr Hamish McMichael Berman Guedes Stretton 9B Ladbroke Grove London W113BD

APPLICATION FOR PLANNING PERMISSION Town and Country Planning Act 1990

DECISION DATE: 4th December 2017

PROPOSAL: Refurbishment of part of University campus consisting of overcladding to ground floor and rebuilding on small ground floor lean-to structure on South elevation ground floor, alterations to main building entrance on North elevation, re-roofing and removal of redundant roof top structures, alterations to remaining roof top structures.

AT: Oxford Brookes University Gipsy Lane Oxford

NOTICE OF GRANT OF PLANNING PERMISSION 17/02631/FUL

Following consideration of the application in respect of the proposal outlined above, it was resolved to GRANT PLANNING PERMISSION for the following reasons:-

1 The Council considers that the proposal accords with the policies of the development plan as summarised below. It has taken into consideration all other material matters, including matters raised in response to consultation and publicity. Any material harm that the development would otherwise give rise to can be offset by the conditions imposed.

2 The Council considers that the proposal, subject to the conditions imposed, would accord with the special character and appearance of the conservation area. It has taken into consideration all other material matters, including matters raised in response to consultation and publicity.

subject to following conditions, which have been imposed for the reasons stated:-

CONDITIONS:

1 The development to which this permission relates must be begun not later than the expiration

www.oxford.gov.uk

18 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 of three years from the date of this permission.

Reason: In accordance with Section 91(1) of the Town and Country Planning Act 1990 as amended by the Planning Compulsory Purchase Act 2004.

2 The development permitted shall be constructed in complete accordance with the specifications in the application and approved plans listed below, unless otherwise agreed in writing by the local planning authority.

Reason: To avoid doubt and to ensure an acceptable development as indicated on the submitted drawings in accordance with policy CP1 of the Oxford Local Plan 2001-2016.

3 Samples of the exterior materials to be used shall be submitted to, and approved in writing by the Local Planning Authority before the start of work on the site and only the approved materials shall be used.

Reason: In the interests of the visual appearance of the Headington Hill Conservation Area in which it stands in accordance with policies CP1, CP8 and HE7 of the Adopted Oxford Local Plan 2001-2016.

4 A Construction Traffic Management Plan should be submitted to the Local Planning Authority and agreed prior to commencement of works. The CTMP should follow Oxfordshire County Council's template if possible. This should identify;

The routing of construction vehicles and management of their movement into and out of the site by a qualified and certificated banksman, Access arrangements and times of movement of construction vehicles (to minimise the impact on the surrounding highway network), Details of wheel cleaning / wash facilities to prevent mud, etc from migrating on to the adjacent highway, Contact details for the Site Supervisor responsible for on-site works, Travel initiatives for site related worker vehicles, Parking provision for site related worker vehicles, Details of times for construction traffic and delivery vehicles, which must be outside network peak and school peak hours, Engagement with local residents, including the adjacent care home.

Reason: In the interests of highway safety and to mitigate the impact of construction vehicles on the surrounding network, road infrastructure and local residents, particularly at peak traffic times.

5 The Sinclair Building shall not be fully occupied in the layout as shown on the drawings hereby approved until new student accommodation for use by Oxford Brookes students has been completed at Cowley Barracks/British Telecom Site, James Wolfe Road or other sites to be agreed in writing with the Local Planning Authority.

Reason: To ensure that the academic and administrative floorspace created by the proposal does not result in an increase in students living in private accommodation and to comply with Core Strategy policy CS25

INFORMATIVES :-

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 19 This includes the offer of pre-application advice and, where reasonable and appropriate, the opportunity to submit amended proposals as well as time for constructive discussions during the course of the determination of an application. However, development that is not sustainable and that fails to accord with the requirements of the Development Plan and/or relevant national policy guidance will normally be refused. The Council expects applicants and their agents to adopt a similarly proactive approach in pursuit of sustainable development.

PLEASE NOTE All local plan policies and proposals which are relevant to this decision are specified in the list below which forms part of this decision notice.

CP1 - Oxford Local Plan 2001-2016 Development Proposals - Sets out key criteria expected from new development.

CP6 - Oxford Local Plan 2001-2016 Efficient Use of Land and Density - Requires development to make maximum and appropriate use of land.

CP8 - Oxford Local Plan 2001-2016 Designing Development to Relate to its Context - Sets out criteria required from development to demonstrate that it will respect the local context.

CP10 - Oxford Local Plan 2001-2016 Siting of Development to Meet its Functional Needs - Sets out criteria required from development to ensure functional needs are met.

CS18_ - Core Strategy Urban design, townscape character and the historic environment - Sets out urban design principles and requires development to respect Oxford’s unique townscape and historic environment.

CS25_ - Core Strategy Student accommodation - Sets out approach to the provision of student accommodation for students at Oxford Brookes University and the University of Oxford.

CS29_ - Core Strategy The universities - Sets out approach to development by Oxford Brookes University and the University of Oxford.

MP1 - Core Strategy Policy requiring the Council to work positively and proactively with the applicant/agent.

HE7 - Oxford Local Plan 2001-2016 Conservation Areas - Identifies Conservation Areas and sets out approach to development within Conservation Areas.

GSP4 - Headington Neighbourhood Plan

CIP1 - Headington Neighbourhood Plan

APPROVED PLANS

20 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Reference Version Description Number 02001 Floor Plans - Proposed 03001 Elevations - Proposed 03002 Elevations - Proposed 03003 Elevations - Proposed 03004 Elevations - Proposed

Patsy Dell Head of Planning, Sustainable Development and Regulatory Services Please quote reference number 17/02631/FUL in all communications

Please note that this notice does not relieve the applicant from the need to ensure compliance with the appropriate provisions of the Building Act 1984 and the Building Regulations 2000. Any planning application which involves alterations to the kerb and construction of a vehicle crossing in the highway (including the footway and/or verge) will require a separate written application to be made to the Director of City Works, Cowley Marsh Depot, Marsh Road, Cowley, Oxford OX4 2HH.

IT IS IMPORTANT THAT YOU SHOULD READ THE NOTES ACCOMPANYING THIS NOTICE

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 21 GUIDANCE NOTES FOR APPLICANTS WHERE AN APPLICATION HAS BEEN APPROVED

1. APPLICATIONS FOR PLANNING PERMISSION, APPROVAL OF RESERVED MATTERS, LISTED BUILDING CONSENT OR CONSERVATION AREA CONSENT.

If you object to the Local Planning Authority’s decision to grant permission, approval or consent subject to conditions, you may appeal to the Secretary of State for the Environment under Section 78 of the Town and Country Planning Act 1990 within 6 months of the date of this notice. With regard to approved applications concerning listed buildings in a conservation area, you may appeal under Section 20 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 8 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990.

Please make your appeal using a form from The Planning Inspectorate, Customer Support Unit, Room 3/15 Eagle Wing, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6PN (Tel. 0117 372 6372) www.planning- inspectorate.gov.uk. The Secretary of State may allow a longer period for you to give notice of appeal, but will normally only do so if there are special circumstances that excuse the delay in giving notice of appeal. The Secretary of State need not consider an appeal if it appears that the Local Planning Authority could have granted permission for the proposed development only subject to the conditions it imposed, bearing in mind the statutory requirements, the development order, and any directions given under the order. In practice, the Secretary of State does not refuse to consider appeals solely because the Local Planning Authority made its decision on the grounds of a direction that he or she had given.

It may be that planning permission, conservation area consent or listed building consent is granted subject to conditions, whether by the Local Planning Authority or by the Secretary of State for the Environment; but you, as the landowner, claim that the land is no longer fit for reasonably beneficial use in its existing state and you cannot make it fit for such use by carrying out the permitted development. If so, you may serve a purchase notice on Oxford City Council requiring the Council to buy your interest in the land. You can do this under Section 137 of the Town and Country Planning Act 1980 or Section 32 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 9 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990 in respect of listed buildings and buildings in conservation areas.

You may claim compensation against the Local Planning Authority if the Secretary of State has refused or granted permission subject to conditions, either on appeal or when the application was referred to her or him. Compensation is payable in the circumstances set out in: (a) Section 114 and Part II of Schedule 3 of the Town and Country Planning Act 1990; or (b) Section 27 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and Regulation 9 of the Planning (Listed Buildings and Conservation Areas) Regulations 1990 in respect of listed buildings.

2. ADDITIONAL NOTES ON LISTED BUILDING CONSENT

1 If you wish to modify the development referred to in your application or to vary it in any way, you must make another application.

2 This notice refers only to the grant of listed building consent and does not entitle you to assume that the City Council has granted its consent for all purposes: (a) If you have applied for planning permission under Section 57(1) of the Town and Country Planning Act 1990, we will send you a separate notice of decision; (b) We will send you a separate notice about plans you have submitted under the Building Regulations 2000; (c) If the development for which listed building consent has been granted includes putting up a building for which you have to submit plans under the Building Regulations 2000, you should not do any work connected with erecting that building until you have satisfied yourself that you have complied with Section 219 of the Highways Act 1980 or that they do not apply to this building.

3 Even if you have gained listed building consent, you must comply with any restrictive covenants that affect the land referred to in the application.

3. APPLICATION FOR CONSENT TO DISPLAY ADVERTISEMENTS

If the applicant is aggrieved by the decision of the Local Planning Authority to grant consent, subject to conditions, he or she may appeal to the Secretary of State for the Environment in accordance with Regulation 17 and Part 3 of Schedule 4 of the Town and Country Planning (Control of Advertisements) (England) Regulations 2007 within eight weeks of the receipt of this notice. (Appeals must be made on a form which obtainable from The Planning Inspectorate, Customer Support Unit, Room 3/15 Eagle Wing, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6PN (Tel. 0117 372 6372) www.planning-inspectorate.gov.uk).

22 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Appendix G – Assumptions behind the Trajectory

The key assumptions in the trajectory are as follows: vi. The occupancy proportions of the third party halls of residences are generally at 80% if the location is i. Under a best-case scenario, a revised Clive Booth Student good, on the basis that Brookes students will not Village (CBSV) scheme is constructed in accordance with have exclusive access under direct let arrangements. the Council's estimations (a net increase of 565 beds); Some third party halls of residence have lower occupancy owing to their more peripheral locations ii. Under a worst case scenario, there is a slight e.g. Slade which is informed by the level of direct lets reduction at CBSV as the 454 end-of-life non-en-suite for this current year. City Centre schemes have lower rooms are replaced by a modest scheme. These rooms occupancy rates again with Student Castle in Osney have already been withdrawn from use in part. The Mead to the west of the railway station registering as reduction is attributed to the need to use larger space zero occupancy. standards and the creation of social/amenity spaces; vii. The University wishes to exit some managed housing iii. Crescent Hall and Marston Road will not come forward arrangements over the same period; in the next 5 years and indeed, the latter may not come forward at all; viii. The scenarios have assumed that by 2026, the University will have a campus population of circa iv. At any point in time, under both scenarios, 150 12,500 students. This in line with the 2010 figures bedspaces are not counted to allow for the temporary around the time of the last demographic bulge and the or permanent decommissioning of bedspaces for capacity of the Oxford estate; refurbishment, consolidation or demolition. This is an important point as draft Policy H8 does not allow for ix. The scenarios assume 22% will live outside of Oxford the net loss of bedspaces; or at home within the City, in line with recent patterns. v. A number of halls of residence operated by third parties will be outside of any compulsory nomination agreements by 2026 (Slade, Dorset, The Mews, Sinnet, Windmill, Beech and Canterbury). Rather than allowing for 100% occupancy that can be expected under nomination agreements, we have assumed a proportion will be occupied by Brookes students on a direct-let basis. For the purposes of the Local Plan, the University cannot commit to continuing nomination agreements unconditionally for a number of reasons:

a. Such a commitment will encourage uncontrolled rent rises for students if the operators know the investment plans of the University are dependent on their commercial arrangement, which would be contrary to the interests of our students

b. The University needs the ability to move away from any third party halls of residence if there is a lack of investment or pastoral care;

c. The University would face reputational damage and be in conflict with its own Students Union if the ability to act on the preceding two issues were beyond its control;

d. The University cannot afford to maintain financial liability for so many bedspaces, particularly as voids do occur.

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 23 Appendix H – The Oxford Brookes University Trajectory

Residential Property Rooms – Best Case - assuming maximum supply of owned rooms

2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Purpose Built Student Accommodation (Owned) Cheney Student Village Operated by UPP 766 765 765 765 765 765 765 765 765 765 Clive Booth non-ensuite CBSV 454 415 369 104 104 0 0 0 0 0 Clive Booth ensuite (N to X) CBSV 791 792 792 792 792 792 792 792 792 792 Clive Booth Postgrad CBSV 368 368 368 368 368 368 368 368 368 368 Clive Booth New build CBSV 0 0 0 0 0 0 0 1,027 1,027 1,027 Paul Kent Hall Hollow Way 242 205 135 0 0 242 242 242 242 242 Crescent Hall Hollow Way 306 306 306 306 306 306 306 306 306 306 Warneford Gipsy Lane 249 249 249 249 249 249 249 249 249 249 Lady Spencer Churchill Wheatley 159 138 159 159 159 Westminster Halls Harcourt Hill 313 313 313 313 313 313 313 313 313 313 Old Harcourt Harcourt Hill 98 98 71 98 98 98 Harcourt N Block Harcourt Hill 21 21 21 21 21 21 21 21 21 21 HIP rooms out of service for refurb -150 -150 -150 Sub-Total - Owned PBSA Properties 3,767 3,670 3,548 3,175 3,175 3,154 3,056 3,933 3,933 3,933 Purpose Built Student Accommodation (Third Party) Slade Park The Slade 367 374 204 170 170 170 170 170 170 170 Dorset House Headington 311 311 311 311 249 249 249 249 249 249 The Mews Cowley Road 112 112 112 112 112 90 90 90 90 90 Sinnet Court Cowley Road 200 200 200 200 200 200 200 160 160 160 Windmill Road Headington 49 49 49 49 49 49 49 39 39 39 Beech House Latimer Road 0 167 167 167 167 167 134 134 134 134 Parade Green Hollow Way 0 0 0 887 887 887 887 887 887 887 Canterbury House Reliance Way 0 48 78 78 78 78 78 62 62 62 Friars Court Marston 30 30 30 30 30 24 24 24 24 24 Thames Street Oxford 78 78 78 78 78 Alice House 50 38 80 30 30 30 30 30 30 30 Castlegate Scheme 31 31 Student Castle Osney Mead 0 0 0 0 0 0 0 Cowley Road Tesco Cowley Road 109 109 109 109 Between Towns Court Between Towns Road 43 43 43 43 43 43 43 Sub-Total Third Party PBSA Properties 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 University Managed and Owned Housing 98 St Clements St Clements 9 9 188 Headington Road Headington 4 4 4 4 4 4 4 4 4 4 192 Headington Road Headington 0 0 4 4 4 4 4 4 4 4 Hill Top House Headington 15 15 15 15 15 15 15 15 15 15 College Close Wheatley 21 21 21 21 11 Head Lease Scheme 311 317 380 392 200 200 200 100 100 100 Sub-Total - Managed and Owned Housing 360 366 424 436 234 223 223 123 123 123 Total rooms Total 5,324 5,443 5,281 5,766 5,502 5,363 5,341 6,053 6,084 6,084 % rooms in owned stock 71% 68% 68% 55% 58% 59% 58% 65% 65% 65% % rooms in non-owned stock 28% 32% 32% 44% 42% 41% 42% 35% 35% 35% Demand Assumption - Modest growth Actual Actual Actual Forecast Forecast Forecast Forecast Forecast Forecast Forecast Full Time student in Oxford Modest growth to 2010 levels 12,263 12,239 12,038 12,104 12,170 12,236 12,303 12,370 12,438 12,506 Less: assumed living at home/not in Oxford (postcode data) 2,759 2,745 2,678 2,662 2,677 2,691 2,706 2,721 2,736 2,751 % assumed living at home 22% 22% 22% 22% 22% 22% 22% 22% 22% 22% Number of students assumed in target 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755 Cumulative Growth 4% Variance 4,180 4,051 4,079 3,676 3,991 4,182 4,256 3,596 3,618 3,671

24 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Purpose Built Student Accommodation (Owned) Cheney Student Village Operated by UPP 766 765 765 765 765 765 765 765 765 765 Clive Booth non-ensuite CBSV 454 415 369 104 104 0 0 0 0 0 Clive Booth ensuite (N to X) CBSV 791 792 792 792 792 792 792 792 792 792 Clive Booth Postgrad CBSV 368 368 368 368 368 368 368 368 368 368 Clive Booth New build CBSV 0 0 0 0 0 0 0 1,027 1,027 1,027 Paul Kent Hall Hollow Way 242 205 135 0 0 242 242 242 242 242 Crescent Hall Hollow Way 306 306 306 306 306 306 306 306 306 306 Warneford Gipsy Lane 249 249 249 249 249 249 249 249 249 249 Lady Spencer Churchill Wheatley 159 138 159 159 159 Westminster Halls Harcourt Hill 313 313 313 313 313 313 313 313 313 313 Old Harcourt Harcourt Hill 98 98 71 98 98 98 Harcourt N Block Harcourt Hill 21 21 21 21 21 21 21 21 21 21 HIP rooms out of service for refurb -150 -150 -150 Sub-Total - Owned PBSA Properties 3,767 3,670 3,548 3,175 3,175 3,154 3,056 3,933 3,933 3,933 Purpose Built Student Accommodation (Third Party) Slade Park The Slade 367 374 204 170 170 170 170 170 170 170 Dorset House Headington 311 311 311 311 249 249 249 249 249 249 The Mews Cowley Road 112 112 112 112 112 90 90 90 90 90 Sinnet Court Cowley Road 200 200 200 200 200 200 200 160 160 160 Windmill Road Headington 49 49 49 49 49 49 49 39 39 39 Beech House Latimer Road 0 167 167 167 167 167 134 134 134 134 Parade Green Hollow Way 0 0 0 887 887 887 887 887 887 887 Canterbury House Reliance Way 0 48 78 78 78 78 78 62 62 62 Friars Court Marston 30 30 30 30 30 24 24 24 24 24 Thames Street Oxford 78 78 78 78 78 Alice House 50 38 80 30 30 30 30 30 30 30 Castlegate Scheme 31 31 Student Castle Osney Mead 0 0 0 0 0 0 0 Cowley Road Tesco Cowley Road 109 109 109 109 Between Towns Court Between Towns Road 43 43 43 43 43 43 43 Sub-Total Third Party PBSA Properties 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 University Managed and Owned Housing 98 St Clements St Clements 9 9 188 Headington Road Headington 4 4 4 4 4 4 4 4 4 4 192 Headington Road Headington 0 0 4 4 4 4 4 4 4 4 Hill Top House Headington 15 15 15 15 15 15 15 15 15 15 College Close Wheatley 21 21 21 21 11 Head Lease Scheme 311 317 380 392 200 200 200 100 100 100 Sub-Total - Managed and Owned Housing 360 366 424 436 234 223 223 123 123 123 Total rooms Total 5,324 5,443 5,281 5,766 5,502 5,363 5,341 6,053 6,084 6,084 % rooms in owned stock 71% 68% 68% 55% 58% 59% 58% 65% 65% 65% % rooms in non-owned stock 28% 32% 32% 44% 42% 41% 42% 35% 35% 35% Demand Assumption - Modest growth Actual Actual Actual Forecast Forecast Forecast Forecast Forecast Forecast Forecast Full Time student in Oxford Modest growth to 2010 levels 12,263 12,239 12,038 12,104 12,170 12,236 12,303 12,370 12,438 12,506 Less: assumed living at home/not in Oxford (postcode data) 2,759 2,745 2,678 2,662 2,677 2,691 2,706 2,721 2,736 2,751 % assumed living at home 22% 22% 22% 22% 22% 22% 22% 22% 22% 22% Number of students assumed in target 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755 Cumulative Growth 4% Variance 4,180 4,051 4,079 3,676 3,991 4,182 4,256 3,596 3,618 3,671

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 25 Residential Property Rooms – Worst Case - Assuming reduction in supply of owned rooms

2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Purpose Built Student Accommodation (Owned) Cheney Student Village Operated by UPP 766 765 765 765 765 765 765 765 765 765 Clive Booth non-ensuite CBSV 454 415 369 104 0 0 0 369 369 369 Clive Booth ensuite (N to X) CBSV 791 792 792 792 792 792 792 792 792 792 Clive Booth Postgrad CBSV 368 368 368 368 368 368 368 368 368 368 Clive Booth New build CBSV 0 0 0 0 0 0 0 0 0 0 Paul Kent Hall Hollow Way 242 205 135 0 0 242 242 242 242 242 Crescent Hall Hollow Way 306 306 306 306 306 306 306 306 306 306 Warneford Gipsy Lane 249 249 249 249 249 249 249 249 249 249 Lady Spencer Churchill Wheatley 159 138 159 159 159 Westminster Halls Harcourt Hill 313 313 313 313 313 313 313 313 313 313 Old Harcourt Harcourt Hill 98 98 71 98 98 98 Harcourt N Block Harcourt Hill 21 21 21 21 21 21 21 21 21 21 HIP rooms out of service for refurb -150 -150 -150 Sub-Total - Owned PBSA Properties 3,767 3,670 3,548 3,175 3,071 3,154 3,056 3,275 3,275 3,275 Purpose Built Student Accommodation (Third Party) Slade Park The Slade 367 374 204 170 170 170 170 170 170 170 Dorset House Headington 311 311 311 311 249 249 249 249 249 249 The Mews Cowley Road 112 112 112 112 112 90 90 90 90 90 Sinnet Court Cowley Road 200 200 200 200 200 200 200 160 160 160 Windmill Road Headington 49 49 49 49 49 49 49 39 39 39 Beech House Latimer Road 0 167 167 167 167 167 134 134 134 134 Parade Green Hollow Way 0 0 0 887 887 887 887 887 887 887 Canterbury House Reliance Way 0 48 78 78 78 78 78 62 62 62 Friars Court Marston 30 30 30 30 30 24 24 24 24 24 Thames Street Oxford 78 78 78 78 78 Alice House 50 38 80 30 30 30 30 30 30 30 Castlegate Scheme 31 31 Student Castle Osney Mead 0 0 0 0 0 0 0 Cowley Road Tesco Cowley Road 109 109 109 109 Between Towns Court Between Towns Road 43 43 43 43 43 43 43 Sub-Total Third Party PBSA Properties 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 University Managed and Owned Housing 98 St Clements St Clements 9 9 188 Headington Road Headington 4 4 4 4 4 4 4 4 4 4 192 Headington Road Headington 0 0 4 4 4 4 4 4 4 4 Hill Top House Headington 15 15 15 15 15 15 15 15 15 15 College Close Wheatley 21 21 21 21 11 Head Lease Scheme 311 317 380 392 200 200 200 100 100 100 Sub-Total - Managed and Owned Housing 360 366 424 436 234 223 223 123 123 123 Total rooms Total 5,324 5,443 5,281 5,766 5,398 5,363 5,341 5,395 5,426 5,426 % rooms in owned stock 71% 68% 68% 55% 57% 59% 58% 61% 61% 61% % rooms in non-owned stock 28% 32% 32% 44% 42% 41% 42% 39% 39% 39% Demand Assumption - Modest Growth Actual Actual Actual Forecast Forecast Forecast Forecast Forecast Forecast Forecast Full Time student in Oxford Modest growth to 2010 levels 12,263 12,239 12,038 12,104 12,170 12,236 12,303 12,370 12,438 12,506 Less: assumed living at home/not in Oxford (postcode data) 2,759 2,745 2,678 2,662 2,677 2,691 2,706 2,721 2,736 2,751 % assumed living at home 22% 22% 22% 22% 22% 22% 22% 22% 22% 22% Number of students assumed in target 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755 Variance 4,180 4,051 4,079 3,676 4,095 4,182 4,256 4,254 4,276 4,329

26 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Purpose Built Student Accommodation (Owned) Cheney Student Village Operated by UPP 766 765 765 765 765 765 765 765 765 765 Clive Booth non-ensuite CBSV 454 415 369 104 0 0 0 369 369 369 Clive Booth ensuite (N to X) CBSV 791 792 792 792 792 792 792 792 792 792 Clive Booth Postgrad CBSV 368 368 368 368 368 368 368 368 368 368 Clive Booth New build CBSV 0 0 0 0 0 0 0 0 0 0 Paul Kent Hall Hollow Way 242 205 135 0 0 242 242 242 242 242 Crescent Hall Hollow Way 306 306 306 306 306 306 306 306 306 306 Warneford Gipsy Lane 249 249 249 249 249 249 249 249 249 249 Lady Spencer Churchill Wheatley 159 138 159 159 159 Westminster Halls Harcourt Hill 313 313 313 313 313 313 313 313 313 313 Old Harcourt Harcourt Hill 98 98 71 98 98 98 Harcourt N Block Harcourt Hill 21 21 21 21 21 21 21 21 21 21 HIP rooms out of service for refurb -150 -150 -150 Sub-Total - Owned PBSA Properties 3,767 3,670 3,548 3,175 3,071 3,154 3,056 3,275 3,275 3,275 Purpose Built Student Accommodation (Third Party) Slade Park The Slade 367 374 204 170 170 170 170 170 170 170 Dorset House Headington 311 311 311 311 249 249 249 249 249 249 The Mews Cowley Road 112 112 112 112 112 90 90 90 90 90 Sinnet Court Cowley Road 200 200 200 200 200 200 200 160 160 160 Windmill Road Headington 49 49 49 49 49 49 49 39 39 39 Beech House Latimer Road 0 167 167 167 167 167 134 134 134 134 Parade Green Hollow Way 0 0 0 887 887 887 887 887 887 887 Canterbury House Reliance Way 0 48 78 78 78 78 78 62 62 62 Friars Court Marston 30 30 30 30 30 24 24 24 24 24 Thames Street Oxford 78 78 78 78 78 Alice House 50 38 80 30 30 30 30 30 30 30 Castlegate Scheme 31 31 Student Castle Osney Mead 0 0 0 0 0 0 0 Cowley Road Tesco Cowley Road 109 109 109 109 Between Towns Court Between Towns Road 43 43 43 43 43 43 43 Sub-Total Third Party PBSA Properties 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 University Managed and Owned Housing 98 St Clements St Clements 9 9 188 Headington Road Headington 4 4 4 4 4 4 4 4 4 4 192 Headington Road Headington 0 0 4 4 4 4 4 4 4 4 Hill Top House Headington 15 15 15 15 15 15 15 15 15 15 College Close Wheatley 21 21 21 21 11 Head Lease Scheme 311 317 380 392 200 200 200 100 100 100 Sub-Total - Managed and Owned Housing 360 366 424 436 234 223 223 123 123 123 Total rooms Total 5,324 5,443 5,281 5,766 5,398 5,363 5,341 5,395 5,426 5,426 % rooms in owned stock 71% 68% 68% 55% 57% 59% 58% 61% 61% 61% % rooms in non-owned stock 28% 32% 32% 44% 42% 41% 42% 39% 39% 39% Demand Assumption - Modest Growth Actual Actual Actual Forecast Forecast Forecast Forecast Forecast Forecast Forecast Full Time student in Oxford Modest growth to 2010 levels 12,263 12,239 12,038 12,104 12,170 12,236 12,303 12,370 12,438 12,506 Less: assumed living at home/not in Oxford (postcode data) 2,759 2,745 2,678 2,662 2,677 2,691 2,706 2,721 2,736 2,751 % assumed living at home 22% 22% 22% 22% 22% 22% 22% 22% 22% 22% Number of students assumed in target 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755 Variance 4,180 4,051 4,079 3,676 4,095 4,182 4,256 4,254 4,276 4,329

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 27 Residential Trajectory: Summary

BEST CASE 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Comments

Owned Purpose Built Student Accommodation 3,767 3,670 3,548 3,175 3,175 3,154 3,056 3,933 3,933 3,933 Third Party Purpose Built Student Accommodation 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 Leased or Owned Housing 360 366 424 436 234 223 223 123 123 123 Total Accommodation (rooms) 5,324 5,443 5,281 5,766 5,502 5,363 5,341 6,053 6,084 6,084

Predicted Full Time Students in Oxford Up to 2010 levels 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755

Assumed Students in Private Rented HMO 4,180 4,051 4,079 3,676 3,991 4,182 4,256 3,596 3,618 3,671 A

WORST CASE 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Comments

Owned Purpose Built Student Accommodation 3,767 3,670 3,548 3,175 3,071 3,154 3,056 3,275 3,275 3,275 Third Party Purpose Built Student Accommodation 1,197 1,407 1,309 2,155 2,093 1,986 2,062 1,997 2,028 2,028 Leased or Owned Housing 360 366 424 436 234 223 223 123 123 123 Total Accommodation (rooms) 5,324 5,443 5,281 5,766 5,398 5,363 5,341 5,395 5,426 5,426

Predicted Full Time Students in Oxford Up to 2010 levels 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755

Assumed Students in Private Rented HMO 4,180 4,051 4,079 3,676 4,095 4,182 4,256 4,254 4,276 4,329 B

Mid-point analysis Diff between A and B 658 Mid point 4,000

28 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 BEST CASE 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Comments

Predicted Full Time Students in Oxford Up to 2010 levels 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755

Assumed Students in Private Rented HMO 4,180 4,051 4,079 3,676 3,991 4,182 4,256 3,596 3,618 3,671 A

WORST CASE 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 Comments

Predicted Full Time Students in Oxford Up to 2010 levels 9,504 9,494 9,360 9,442 9,493 9,545 9,597 9,649 9,702 9,755

Assumed Students in Private Rented HMO 4,180 4,051 4,079 3,676 4,095 4,182 4,256 4,254 4,276 4,329 B

Mid-point analysis Diff between A and B 658 Mid point 4,000

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 29 Appendix I – Oxford Mail Article 7th June 2019

‘Oxford Brookes student block plan “The first is the public benefit issue that homes will go to [the market]. That can’t be proven.” thrown out’ He added: “The (council’s) paper makes clear that the A HUGE overhaul of Oxford Brookes University’s student impact is moderate to the city as a whole if you’re far accommodation was unanimously rejected by councillors away…but the nearer you get to it the more substantial the over concerns it could badly affect Headington. impact is.

The university wanted to knock down eight “This cannot be compatible with the distinctiveness of a accommodation blocks and replace them with taller ones local area in terms of scale, orientation and mass. There – including a seven-storey unit – at its Clive Booth Student would be scheme that would [be], but it’s not this.” Village. Ahead of the meeting on Wednesday night, the Oxford There are currently 640 bedrooms at the Headington Preservation Trust had been opposed to the development. complex, which first opened in the 1970s. After the work, there would have been 1,077 bedrooms. An Oxford Brookes spokeswoman said: “We are disappointed that planning has not been approved despite However on Wednesday night councillors agreed the a recommendation for approval by officers. damage to the Headington Hill Conservation Area and to the wider city was not worth the possible public benefit. “We will consider our next steps in relation to this proposed development which would benefit students and the wider The council’s East Area planning committee was community. unconvinced by a claim backed by planning officers that 246 homes would be released back onto Oxford’s housing market because students would not need them.

During a fractious meeting at Oxford Town Hall, a member of the public opposed to the plan labelled that ‘pie in the sky’.

He shouted: “I’ve listened to enough rubbish.”

More than 100 residents had formally opposed the project, with one telling the council they worried it could ‘form a ghetto’.

Labour councillor Nigel Chapman said: “This case is a finely balanced one and the planning officers have given the benefit of the doubt to it. When you start to unpick it more thoroughly, some of the crutches on which it’s based become rather flimsy.

30 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Appendix J – [Extract] The Inspector’s Report into the 2013 Sites and Housing DPD (3rd January 2013)

42. Consistent with this CS concern, this issue is picked consider that the principle of policy HP6 is sound. up in paragraph A2.37 of the Plan, and Policy However, there is insufficient justification to HP6 aims to address it by seeking provision for extend its application to other residential uses affordable housing from student accommodation not falling within Class C3, as suggested in some development. Legal submissions were made in representations, because the evidence does not written representations and at the hearings on indicate that those uses compete significantly behalf of the Oxford University Colleges regarding with potential general purpose housing sites. their perceived inconsistency of this policy with the CS. The crux of these submissions is that neither CS 45. However, there are several shortcomings with policy CS24 nor any other saved LP policy requires the precise wording of the submitted policy provision for affordable housing from student and its supporting text that make it ineffective, accommodation development. Furthermore, it is which would be rectified by (MM6). This main argued that policy HP6 is internally inconsistent modification would raise the qualifying threshold because it does not seek such provision from other from 8 to 20 student bedrooms, because in non- Class C3 residential uses. practise it is unlikely that schemes falling within the smaller threshold would come forward. For 43. I do not support those arguments. Policy HP6 flexibility and consistency with the Framework is consistent with the CS because it is clearly on-site provision for affordable housing would be consistent with Objective 1 of the Plan, which permitted where it is agreed by the Council and in turn is consistent with the Spatial Vision and the developer that a mix of student and general Strategic Objective 7 of the CS. Moreover, I do not purpose housing would be appropriate. Provision consider that the challenge takes into account the for negotiating the scale of financial contribution subtle change from the hierarchical relationship made to take account of viability considerations that was required between development plan would also be added to the policy text. documents by the now revoked Planning Guidance Note 12 and the requirements of paragraph 153 46. In addition, to ensure that the policy, in of the Framework, which does not entail the combination with policies HP5 and CS25, does ranking of a suite of documents, but requires the not swing the balance too heavily in favour of production of a single local plan, with other plans general purpose housing to the extent that the being produced only where clearly justified. The ability of the two Universities to expand and justification for the Plan is, amongst other matters, compete internationally with other universities the need for policies to address the urgent need is compromised, the exceptions to the policy to maximise delivery of an appropriate mix of high would be clarified and extended. Additional quality housing in Oxford, including that which is exceptions would apply to sites that are allocated affordable. solely for student accommodation in the Plan, or proposals to redevelop/intensify student 44. Alternative methods and levels of delivery of accommodation on a site with a main existing use affordable housing from student accommodation for student accommodation, or on contiguous development have been tested, including the 50% adjoining land. However, this does not infer that on-site provision that would be required by HP3 all such contiguous land is suitable for student and the financial contribution formula detailed in accommodation. Such proposals for student Appendix 2, but they have been rejected because accommodation would first need to pass the they are not clearly viable. However, the CBRE location tests of HP5 before the proposals are Study demonstrates that the level of financial assessed against HP6. The exceptions also apply contribution sought from policy HP6 for off-site where the proposed student accommodation is affordable housing provision, which is set out in necessary to enable either University to achieve Appendix 4 of the Plan as a formula based on the or maintain its 3,000 student numbers threshold student accommodation floorspace proposed, referred to in CS policy CS25, or where the Council is appropriate, justified and viable in most of the agrees that the site is not suitable for, nor capable cases tested. The formula provides flexibility to of being made. take account of specific viability issues and it clearly relates the scale of the contribution sought to the scale of the development proposed. Thus I

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 31 Appendix K – Policy HP6, Sites and Housing DPD

Appendix J – Policy HP6, Sites and Housing DPD

32 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019

Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 33 34 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 Oxford Local Plan – Matter 5: Housing for Particular Groups Oxford Brookes University Written Statement November 2019 35 41-43 Maddox Street London W1S 2PD Tel: 020 7493 6693 www.turnberryuk.com