Planning Policy Vale of White Horse District Council 135 Eastern Avenue Milton Park Milton OX14 4SB
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Planning Policy Vale of White Horse District Council 135 Eastern Avenue Milton Park Milton OX14 4SB Our ref: VOWHDC. 27.03.2019. OBU_HH Your ref: North Hinksey Neighbourhood Plan 27th March 2019 Dear Sir/Madam, North Hinksey Parish Neighbourhood Plan 2031 submission Representations on behalf of Oxford Brookes University We write on behalf of Oxford Brookes University in respect of their Harcourt Hill Campus which falls within the Parish of North Hinksey and therefore the Neighbourhood Plan area. We have previously engaged directly with the Neighbourhood Plan group in response to their consultation in August 2018 and subsequently suggested amendments to their plan through informal discussions in November 2018. Few changes have been taken on board and we provide our previous representations as Appendix A (August 2018) and Appendix B (November 2018) to this letter. The University maintains its objeCtion to the North Hinksey Parish Neighbourhood Plan as it fails to meet the basic conditions necessary to be ‘Made’. Our previous concerns that the Neighbourhood Plan lacks resilience still stand in that the current campus is operating below its historic optimum capacity but is restricted in its ability to move back to sustainable levels, which would support the associated sports facilities enjoyed by the community. In short, the plan is not prepared positively, will not accomplish its objectives and has not been prepared with early and effective engagement in mind. It is therefore contrary to paragraph 16 of the NPPF and thus fails the Basic Conditions. North Hinksey Neighbourhood Plan Oxford Brookes University 27th March 2019 The key points we have made in respect of the North Hinksey Neighbourhood Plan and have been unaddressed are as follows: • The Plan should clearly identify Oxford Brookes University Harcourt Hill Campus with a defined planning use, rather than as Major Social Infrastructure and Public Green Spaces. Its social and public open space characteristics are not the same as those pertaining to other land outwith the campus. • Policy BU1 should be clarified to ensure that development is limited to the existing built up area of the Campus and not the existing building footprint. • Point (d) of policy BU1 which encourages development to ‘keep any expansion of buildings within the present Green Belt boundaries and the major development site boundary of the campus as indicated on the Oxfordshire County Council map of the site included as Map H.1 in the Appendices of this document’. This policy requirement is contrary to the requirements of paragraph 145 of the NPPF which defines the exceptions where development is not inappropriate in the Green Belt. The policy currently undermines the strategic policies of the NPPF and adopted policy CP9 of the adopted VOWHDC Local Plan Part 1 by promoting less development than set out in the strategic policies for the area. • Policy BU1 (a) also seeks to impose an arbitrary limit to an increase in student, staff and the general public travelling to the site with no evidence to support it. This limit to 20% increase over the base line usage in 2010 means that the policy could restrict usage rates below what is needed for a viable campus in the future. • Policy UT2 should be deleted as it is against national policy for Neighbourhood Plans to identify energy efficiency standards (Written Ministerial Statement 2015). • The Neighbourhood Plan does not propose a collaborative and constructive approach for the future of the Harcourt Hill Campus as is set out by the VOWHDC Local Plan 2031. • Policy SI1 refers to the Campus as social infrastructure. This is a private site that is run as a higher education institution, although the sports facilities are opened for use by the general public as supplementary to the students and staff of the University. • Contrary to paragraph 2.2.7, Oxford Brookes are not the landowner of the Harcourt Hill Campus, they are long lease holders. This should be rectified. 2 North Hinksey Neighbourhood Plan Oxford Brookes University 27th March 2019 In its present form, the submission version North Hinksey Parish Neighbourhood Plan is flawed, though it depends heavily on the availability of sporting facilities provided on the campus. The local community is a major user of the facilities at Harcourt Hill sports, and usage by the public is around 4/5th of total membership. However, the total running costs of the facilities far outstrip the income that the Sports facilities generate. There is a funding gap of around 25% between income and costs for the facility, meaning that the University are heavily subsidising the facility in order to maintain it for use by staff and students, without accounting for additional capital investment that is needed from time to time. The viability of the site as a campus is essential to the presence of the facilities enjoyed by the community. In summary, the Plan is very dependent on the University funding and investing in sporting facilities, whilst at the same time seeking to limit the extent to which the University is able to invest in the site to support these facilities. It does this by applying additional controls over development in the Green Belt which go beyond the Local Plan and NPPF as well as setting limits of use over the site without any evidence explaining from where they are derived and why they are necessary. The Plan is therefore not in conformity with the planning framework and fails to meet the basic conditions. We would reiterate the need for a detailed discussion between the Neighbourhood Plan Group and the University before this Plan progresses to the next stage. Yours sincerely, Chris Pattison 3 North Hinksey Neighbourhood Plan Oxford Brookes University 27th March 2019 Appendix A: Letter dated 2nd August 2018 – response to final public consultation of Draft North Hinksey Parish Neighbourhood Plan 2031 4 North Hinksey Parish Neighbourhood Plan C/O 17 Poplar Road Botley Oxford OX2 9LA Our ref: OBU-NHPNP 02.08.2018 Your ref: 2nd August 2018 Dear Sir/Madam, North Hinksey Parish Neighbourhood Plan 2031 Response to Final Public Consultation We write on behalf of Oxford Brookes University in respect of their Harcourt Hill Campus, which includes their Brookes Sport facility. Oxford Brookes University welcomes the ambitions of the Neighbourhood Plan Forum in creating a Neighbourhood Plan. The University has engaged with the local community and the Neighbourhood Plan preparation process, presenting an update to community representatives on its plans to develop its Harcourt Hill Campus in October 2017. Although the future aspirations of the Campus have not been finalised yet, the University is concerned that the proposed Neighbourhood Plan lacks resilience given that it relies heavily on the status quo and restricts the ability of the University to invest in its campus, maintaining services that the community also enjoys. The University therefore reluctantly objects to the Draft North Hinksey Parish Neighbourhood Plan as it fails to meet the basic conditions necessary to be ‘Made’. Our main concern is that the Plan fails to engage with Oxford Brookes as an institution active within the Neighbourhood Plan Area. The Plan merely seeks to restrain the University in the context of its existing operation and physical form and does not allow or recognise that the campus will need to evolve in line with the objectives of the University. This issue is best illustrated on Map 1.2, which incorrectly identifies Harcourt Hill Campus as Major Social Infrastructure and Public Green Spaces. This plan is factually incorrect and should clearly identify North Hinksey Parish Draft Neighbourhood Plan Turnberry 2nd August 2018 Oxford Brookes University Harcourt Hill Campus with a defined planning use under the control of the University. Its social and public open space characteristics are not the same as those pertaining to other land outwith the campus. This is reaffirmed in respect of the lack of consultation with Oxford Brookes University despite the statements made in respect of Section 1.3, but more so in that the University, as the largest landowner and provider of community infrastructure, is omitted from the Vision set out in Section 2. Therefore the University wishes to make comments on the Draft North Hinksey Parish Neighbourhood Plan 2031, particularly in respect of Policy BU1. Policy BU1 – Oxford Brookes Harcourt Hill Campus, states the following: “The masterplan and any subsequent proposals must clearly identify and address the key issues of the site as laid out in The Vale of White Horse Local Plan 2031 Core Policy 9 (Harcourt Hill Campus) in a manner that is compatible with Core Policy 13 (The Oxford Green Belt), Core Policy 38 (Design Strategies for Strategic and Major Development Sites), and Core Policy 44 (Landscape) and should be prepared to a standard suitable for adoption as a Supplementary Planning Document also including but not limited to the following matters: i) A transport assessment and travel plan for the scale of development proposed in accordance with VOWHDC Local Plan 2031 Core Policies 33 and 35 which should address the transport and travel issues associated with access the site (see NHPNP Policies TR1 to TR5 with regard to transport and traffic constraints and Oxfordshire County Council consultation reply to OBU draft masterplan 2012). Where necessary to enable development, contributions should be sought by planning condition to the maintenance of local road and pavements in the area. ii) A landscaping and tree planting strategy to ensure the integration of built form into the landscape (see NHPNP policy GS2 with regard to the overall prominent landscape setting of the campus) and to maintain the rural aspect of the Campus and views across Oxford from the surrounding hills and designated view cones of the Oxford Local Plan and the Oxford City Council Assessment of the Oxford View Cones 2015.