Planning Policy District Council 135 Eastern Avenue Milton Park Milton OX14 4SB

Our ref: VOWHDC. 27.03.2019. OBU_HH Your ref: Neighbourhood Plan

27th March 2019

Dear Sir/Madam,

North Hinksey Parish Neighbourhood Plan 2031 submission

Representations on behalf of 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 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.

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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

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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

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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. iii) A Flood Risk assessment and Drainage Strategy to be prepared for the whole

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Campus to ensure that the scale of development proposed does not adversely impact on the local and wider network. (see NHPNP section 4.5 Utilities with regard to flooding and drainage)

Development will be supported if: (a) It contributes towards sustainable modes of transport which access the Campus, does not increase the number of car parking spaces on the Harcourt Hill Campus site as a whole, and will not result in a significant* increase in student, staff and general public numbers travelling to the site. (b) For new housing or student accommodation on site, it can be demonstrated that these will only be used for students of staff of Oxford Brookes University, and will be predominantly (a minimum of 75% of the total housing units) for the use of staff and students principally assigned to work at this campus. *Significant being a 20% increase over the base line usage in 2010 as noted in the Oxford Brookes University Student numbers report December 2015.

Development will be encouraged to: (c) Have planning and design of architectural merit as in the VOWHDC Local Plan 2031 part 1 and the Vale of White Horse District Council Design Guide March 2015, with buildings appropriate to the location in line with the North Hinksey Parish Character Assessment (January 2018). (d) Keep any expansion of buildings within the present Green Belt boundaries and built footprint of the campus (e) Utilise sustainable means of utilities and services including but not restricted to energy, waste and surface water (NHPNP Policy UT2)”

Development within the Green Belt Policy BU1 encourages development within the Green Belt to be limited to the built footprint of the campus. Chapter 13 of the NPPF (published July 2018) details the overarching national policies for protecting land within the Green Belt, paragraph 145 specifically outlines new buildings that are not considered inappropriate within the Green Belt. These have been provided below:

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a) “buildings for agriculture and forestry; b) the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it; c) the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; d) the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces; e) limited infilling in villages; f) limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); and g) limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would: - not have a greater impact on the openness of the Green Belt than the existing development; or - not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority.”

These policies are reflected in Core Policy CP13 of The Vale of White Horse District Council’s (VOWHDC) Local Plan 2031 (Part 1); however with more specific references to the District, specially stating “Development will be permitted…(in North Hinksey), which (is) inset into the Green Belt, where the proposed development is within the existing built area of the village”. We note that proposed Policy BU1 identifies that a masterplan should be developed in a manner that is compatible with the VOWHDC’s Local Plan including Policy CP 13. The full policy is included below for completeness.

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North Hinksey Parish Draft Neighbourhood Plan Turnberry 2nd August 2018

Figure 1: VOWHDC Local Plan 2031 (Part 1) Core Policy 13

Point (g) of the NPPF and (vii) of the VOWHDC Local Plan are relevant to the Oxford Brookes Harcourt Hill Campus as it is a “previously developed” site. Therefore, under these policies, further infill development at the Campus is not considered inappropriate where the resulting development will, “not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development”.

The definition of “openness” has been the subject of many debates in planning case law and its assessment is not limited to the footprint of existing buildings. We refer to a recent decision of the and Wales High Court of the Appeal in Euro Garages Limited vs The Secretary of State for Communities and Local Government and Cheshire West and Chester Council (Case No: CO/145/2018), where the decision to dismiss an appeal was quashed and sent back to the secretary of state for redetermination. The original planning application related to a proposed extension to a service station located within the Green Belt. In the High Court decision, the judge ruled that when assessing the impacts of a development on the openness of the Green Belt “a mere change in the current build is not sufficient to establish that there is a greater impact on the

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openness of the Green Belt”. She goes on further to say that, “where openness of the Green Belt is in issue, visual impact, as well as spatial impact, requires consideration, subject to a margin of appreciation”.

The policy as it currently stands is open to ambiguity in how it can be interpreted for future development by the University at their Harcourt Hill Campus. We would suggest that the policy wording is clarified to ensure that development is limited to the existing built up area of the Campus, and not to the existing building footprint. Policy BU1 should also require an assessment that considers the visual and spatial impacts subject to sound planning judgement which would ensure it aligns with the need for development to not impact on the openness of the Green Belt any more than existing. We therefore request that point (d) of the policy is removed entirely as it does not support the Local Plan and NPPF Policies.

Transport Impacts Policy BU1 of the Draft Neighbourhood Plan seeks to limit the number of staff, students and general public travelling to the site by no more than 20% of the baseline usage figure in 2010 as noted in the Oxford Brookes University Student numbers report December 2015. The Plan cites traffic issues as the justification for enforcing this limitation. Firstly, the document referenced within the policy, which defines the baseline usage figure in 2010 of the University has not been evidenced by the Parish, nor is it available for review. Therefore the initial baseline usage figure is indefinable and presents ambiguity when attempting to calculate “significant growth” of the University. Secondly, there is no evidence provided by the Parish to suggest that an increase in patrons visiting the Campus in excess of 20% will result in detrimental impacts on the local road network.

Student numbers at the Oxford Brookes University Harcourt Hill Campus has historically fallen. The headcount of the Campus in 2005/6 was 4,054 and 2,672 FTE and in 2016/17 the headcount was 2,000 and 1,588 FTE. This represents a decrease in FTE students of 41% and overall student bodies of 51%. This has resulted in lower utilisation levels across the Campus (approximately 11%), which is well below the sector average of 36%. This demonstrates that, historically, the Campus has experienced higher volumes of staff and students visiting the site, which has not compromised the local road network.

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We would therefore suggest that the reference to the 2010 baseline usage figure as noted in the Oxford Brookes University Student Numbers Report, December 2015 is removed on the basis there is no evidence to support it, contrary to planning policy guidance and the fulfilment of the ‘basic conditions’. Point (a) of Policy UB1 should therefore be revised as follows: “It contributes towards sustainable modes of transport which access the Campus, does not increase the number of car parking spaces on the Harcourt Hill Campus site as a whole, and will not result in a significant* increase in student, staff and general public numbers travelling to the site is supported by a Transport Assessment and Travel Plan.”

Furthermore, the policy also suggests that contributions should be sought through planning conditions for the maintenance of local road and pavements in the area, presumably through a s106 agreement. The Vale of White Horse District Council outlines the procedures for applying for funding from a s106 agreement. It states that funding for project should “be a capital project (funds cannot be used for revenue towards on-going running costs or minor repair works”. As such, it is not legal to secure funds for the maintenance of local roads and pavements through a condition. This requirement should be deleted.

Basic Conditions Test A draft Neighbourhood Plan or Order must meet the basic conditions as set out in paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990. An assessment of the proposed Neighbourhood Plan against the basic conditions has been carried out below. A Neighbourhood Plan meets the basic conditions if: having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the order,

As discussed above, the neighbourhood plan does not have due regard to NPPF’s policies on development within the Green Belt and therefore does not have regard to the national policies and advice.

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the making of the order contributes to the achievement of sustainable development, The draft plan has the potential to limit the long term success of Oxford Brookes University at its Harcourt Hill Campus by seeking to set unfounded caps to student and staff numbers as well as restricting its built form. The University is a major contributor to the local economy and labour force and its campus services delivered primarily for the benefit of its staff and students, directly benefits local residents. On the one hand, the Plan restricts and limits the success of the University at Harcourt. The Neighbourhood Plan will not allow Oxford Brookes to continue operating at the campus and this could lead to its closure. The Neighbourhood Plan appears to be working against its own vision in order to create an unsustainable strategy. Therefore, it is considered that the draft plan does not contribute to the achievement of sustainable social and economic development and thus does not comply with this basic condition.

the making of the order is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area), Part 1 of the Vale of White Horse Local Plan 2031: Strategic Sites and Policies was adopted in December 2016. Part 2 of the Local Plan: Detailed Policies and Additional Sites was submitted for independent examination on 23rd February 2018 and the hearing commenced on 3rd July 2018. Core Policy 9 of the Local Plan supports the “upgrading or re-development” of Oxford Brookes’ Harcourt Hill Campus through a masterplan process. It states that, “The Council will work proactively with Oxford Brookes University, Oxfordshire County Council, local residents and other appropriate stakeholders to help the university develop a masterplan for the Harcourt Hill Campus site that meets the university’s longer term business needs”. The masterplan should consider the scale of development and intended uses, integration within the landscape, sustainable site access (public transport, car parking, public transport etc.) and the long distance views of the site from Oxford City.

The Local Plan also supports the enhancement and development of higher education facilities through Core Policy 30, which seeks “to help support the local economy and to

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ensure the local labour force is equipped to take advantage of the opportunities likely to arise in the future”.

Policy BU1 of the Neighbourhood Plan seeks to place arbitrary limits on the University’s Harcourt Hill Campus to less than 20% of its 2010 baseline usage figure, and built form to within the existing footprint. This will hamper the success of the institution and its ability to continue supporting facilities and the environment that the community enjoys. On the basis the Neighbourhood Plan is not proposing a similar collaborative and constructive approach set out in the Strategic policy, the proposed Neighbourhood Plan does not meet point (e) of the basic conditions test as it conflicts with the strategic policy contained within the VOWHDC Local Plan 2031.

Key Views

We note that a “valued” view has been identified along the private road located within the Harcourt Hill Campus (VP11) and is protected under Policy GS3 of the Draft Neighbourhood Plan. Aside from its description, “from the private road into Brookes Sport looking towards Hurst and ”, there is no other justification provided within the documents as to why this is considered an important view. The Character Assessment provided as a supporting document does describe views within the Harcourt Hill area; however only mentions short distance views along Vernon and Stanton Road that are, “in effect attractively leafy country lanes running past spacious private gardens”. VP11 is not located along either of these roads and is positioned behind the student accommodation buildings in the southeast portion of the Campus and offers views over the Brookes Sports fields. As such, we would do not see any strategic benefit in identifying this view as “locally important”: the view identified offers little to no positive features, is limited in extent and lacks historical, landscape, social and cultural significance, and is not characterised as a leafy country lane within the Character Assessment.

Summary In its present form, the draft North Hinksey Parish Neighbourhood Plan is flawed. It is dependent on the University investing in generous sporting facilities but is seeking to limit the extent to which it can invest in the campus to make these services sustainable. Indeed, its restrictions depart

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from accepted approaches to the assessment of development in the Green Belt. Further, an assessment of the site’s capacity, in terms of traffic and population, has not been undertaken as part of the Neighbourhood Plan exercise and therefore there is no evidence to support limits imposed by the Plan, particularly considering the historic populations of the Campus.

Additionally, the plan does not meet the basic conditions test set by the Town and Country Planning Act 1990 in that it does not support the strategic policies of the Local Plan, conflicts with the NPPF and does not contribute to sustainable development due to a lack of social and economic benefits. As such, the proposed Plan should not be approved and should be revised to address these fundamental flaws. Once again, we would like to re-iterate that the University supports the objectives of the Neighbourhood Plan Forum, but fears that its strategy is not sustainable or resilient and potentially unsound.

We trust that these comments will be looked at carefully before the Neighbourhood Plan proceeds and that the Forum will seek to consult with the University to a greater extent.

Yours faithfully,

Chris Pattison

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North Hinksey Neighbourhood Plan Oxford Brookes University 27th March 2019

Appendix B: Letter dated 16th November 2018 – North Hinksey Parish Neighbourhood Plan 2031 suggested amendments

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NHNP Suggested Amendments 16th November 2018

North Hinksey Parish Neighbourhood Plan 2031 suggested amendments

The following suggested amendments are submitted on behalf of Oxford Brookes University in relation to specific policies that refer to their Harcourt Hill Campus in the Draft North Hinksey Parish Neighbourhood Plan 2031. The amendments have been expressed through track changes and relate mainly to the wording within Policy BU1 and part 2.1 of the Draft Neighbourhood Plan, “Neighbourhood Plan Vision”. This document should be read in conjunction with our original representation dated 2nd August 2018.

Front Cover:

Achieving controlled, sustainable and appropriate positively planned, sustainable development.

1.1 Introduction

Given all of the above, it is slightly surprising that in fact North Hinksey Parish has a strong sense of community and local identity, a good record of participation, an active Parish Council, good levels of local communication (including a free monthly magazine called ‘The Sprout’ distributed to all parishioners, and a comprehensive Botley and North Hinksey Community website), and a high level of long-term residents. Overall it has a well-balanced and integrated mix of residents from a socio- economic and cultural viewpoint, and is not overly dominated by any particular grouping in the way that has occurred historically within other areas of Oxford (e.g. University students, nurses, workers at the car plant). The community is also able to have access to the sport and recreational facilities at Oxford Brookes University’s Harcourt Campus. The University is the largest single stakeholder within the Parish. One other significant grouping that should be recognised, however, is the elderly. The higher than average numbers of residents in the 70 plus age group do have specific requirements that should be recognised and catered for within the community.

1.2.3 Area Designation and Current Land Use Maps:

As indicated on Map 1.1 below (the designation area map), the eastern boundary of the Parish with Oxford City mainly follows the Stream, an offshoot of the Thames. To the south lies the Parish of , but there are no direct physical ties between these two Parishes, with open fields and golf course lying between the two, and no direct local road connecting them. To the west lies

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Cumnor Parish, with the seemingly arbitrary western boundary running north to south a short distance to the west of the West Way / Eynsham Road / junction.

The following Map 1.2 provides a simplified view of current land use combined with an indication of areas within the Green Belt. This clearly shows the following: Green Belt land covering most of the southern half of the Parish, and a small area next to the A420 in the north, Commercial sites concentrated in the north-east of the Parish around the West Way / A34 junction, A number of major social infrastructure sites to the east of the Parish close to the A34 and in an arc to the south-west running from the Louie Memorial Fields via Brookes University Harcourt Hill site to Raleigh Park, with most of this land falling within the Green Belt, Oxford Brookes University’s Harcourt Hill Campus, Areas of farmland mainly to the south-east of the Parish, with a small area next to the A420, virtually all within the Green Belt, The majority of the housing lies in the centre and towards the north-west of the Parish.

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Map 1.2 – Current Land Use within North Hinksey Parish, plus the Green Belt

Define Oxford Brookes University Campus on this plan and separate it out in the key

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1.2.4 Parish Character Assessment and Additional Parish Maps:

A separate detailed North Hinksey Parish Character Assessment (final version January 2018) has been produced by the Neighbourhood Plan team. In addition to featuring a more detailed history of the local area and its development over the ages, this document identifies the following Character Areas within North Hinksey Parish: 1. West Way / Botley Centre 2. Old Botley 3. Seacourt Tower and Retail Park 4. Westminster Way 5. Elms Rise Estate 6. Cumnor Rise 7. North of West Way 8. North Hinksey Village 9. Harcourt Hill including Oxford Brookes Harcourt Campus 10. Tilbury Fields Estate

1.2.5 North Hinksey Parish as a Functional Unit:

In terms of functionality there are significant connections with both Cumnor Parish and Oxford City covering many aspects of life. In particular the following should be noted: • Despite the name of the Parish, most residents living outside of North Hinksey Village itself would describe themselves as living in ‘Botley’ rather than North Hinksey as Botley incorporates all of the Character Areas listed above apart from area 8. • There is a considerable throughflow of traffic from Cumnor Parish into the Parish as well as from residents of North Hinksey Parish into Oxford City and onto the A34 (primarily for work, shopping and leisure purposes), which impacts strongly on local road conditions. • Retail and leisure sites within North Hinksey Parish itself are also used heavily by residents of Cumnor Parish, particularly those living in Dean Court and Cumnor Hill, many of whom would feel more closely associated with ‘Botley’ than with Cumnor Village or Cumnor Paris. • North Hinksey Parish has no secondary school within its boundaries, but Matthew Arnold School lies immediately outside the western boundary, within Cumnor Parish, and many North Hinksey children are educated there. Similarly, many younger children living in Cumnor Parish and West Oxford attend the two Primary Schools located within North Hinksey Parish. • Oxford Brookes University has a campus at Harcourt Hill, which, following the closure of Wheatley will be its second campus. Headington Hill is the University's main campus in east Oxford. The two campuses are connected with cross-City direct bus connections that also serve the local community. The presence of the

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campus also means that staff, students and visitors contribute to the vibrancy of existing commercial and retail services within the Parish.

2.1 Neighbourhood Plan Vision:

By 2031, North Hinksey will be an inclusive Parish of high quality design containing a wide-ranging mix of services and facilities, both including commercial, education and social, to service the local community. It will foster diverse employment and a healthy economy. It will encourage, and improve the infrastructure for pedestrians, cyclists and public transport, and reduce reliance on private car journeys. It will make best use of utilities, and benefit from new low carbon and energy-efficient technologies. It will protect and enhance its green spaces, wildlife, and the semi- rural nature of its location. It will retain its own identity and role within the Vale of White Horse, and its historic setting, while at the same time developing its relationship with neighbouring Oxford City.

4.1.3(b) Redevelopment/ Extensions to Current Housing, and Densification

This second section relates to changes on existing sites and extensions to existing properties. Much current development involves extensions of existing houses to the rear or into the roof. On larger plots the existing house is demolished and replaced with two or more houses. Significant parts of the Parish are characterised by post-war 'custom built' housing, and this form of housing redevelopment is encouraged but not at the expense of the Parish's green character.

A series of sites were investigated following public consultation. These have been set out in Table B.1 in Appendix B – Housing. No major sites for housing were identified. All the site have constraints, most related to Green Belt and flooding issues. This currently limits NHPNP to respond to existing housing pressure; and therefore the housing policies are geared mainly to maintaining the green character of the Parish and ensuring over development does not take place. Sites 7 to 9 listed in Table B.1 in Appendix B – Housing relate to two potential significant redevelopments, namely of Oxford Brookes University Harcourt Hill Campus and of Field House. As Field House lies within Botley Centre it is considered further in section 4.1.3(c) below, however the Harcourt Hill Campus is covered in this section. A major exercise is currently being carried out by Brookes to develop a masterplan for redevelopment of the Harcourt Hill Campus (of which sites 7 and 8 form a part) in line with the Local Plan Core Policy 9. The Local Plan Inspector stated that all development (including any housing / accommodation) must be sited within existing Brookes developed boundaries, an approach which the Local Plan and this Neighbourhood Plan uphold. The development of

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the site for housing / accommodation or buildings for any other purpose would need to take these comments into account as well as the needs of the University along with the following: This alone would make specific development of sites 7 and 8 (for housing / accommodation or buildings for any other purpose) unviable, a situation which is reinforced by other factors as follows. The whole Harcourt Hill Campus lies within the Green Belt, which needs to be taken into account in line with the Local Plan Core Policy 13 on this topic as does the loss of existing playing fields. In addition, Policies SI1, GS1 and GS2 of this Plan would require the removal of any playing fields to be matched by relocating that facility elsewhere on the Campus. Overall the redevelopment of the Harcourt Hill Campus will need to meet the requirements of Policy BU1, which in this context requires any accommodation to be used primarily for students, academics and staff based on the Campus. The level of housing / accommodation on the Campus will also be limited by subject to the potential impact on transport in the vicinity, and careful attention will need to be taken of Transport Policies TR1 to TR5 to ensure compliance. In practical terms any development on the current car park would require similar facilities to be provided elsewhere on the Campus. See section 4.7 of this Plan for further details about the Brookes Harcourt Hill site.

Policy TR1 – Cycling, Pedestrians and Public Transport

Require that contributions are sought for any development within 300 metres from existing public transport services for improved infrastructure for new public transport including real time information at all bus stops, or alternatively, ongoing investment in bus services.

Policy SI1 – Leisure and Social Facilities

Delete Oxford Brookes from the list of Social Facilities (SF4), unless the plan can be specific as to what aspect is important. The tests listed are also not compliant with paragraph 97 of the NPPF.

Policy UT2 – Sustainable Design, Energy Efficiency and Renewable Energy:

Delete this policy as it is against national policy for Neighbourhood Plans to identify energy efficiency standards (Written Ministerial Statement 2015).

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4.6.3 Further justification and evidence, and Green Spaces & Natural Environment Policies: There will be a strong presumption against housing or commercial building on the Local Green Spaces in line with the National Planning Policy Framework. A map showing locations of all sites is included as Appendix G Map G.1. These sites are defined under the criteria set out in the National Planning Policy Framework. Their assessment against the criteria is provided in Appendix G Table G.1. The Local Green Spaces referenced in the Neighbourhood Plan are sites outside of the Oxford Green Belt and are therefore not protected under Green Belt legislation. The grassed areas and verges designed into the Elms Rise estate are an important feature and contribute to its character, adding to the distinctive open feel, enhancing views over the hillside and reinforcing the sense that you are in a semi- rural area. Comments received after the October 2017 consultation event highlighted residents’ concerns that the views to and from the Parish need to be protected, identifying the easterly views towards the city of Oxford, and the northerly views towards open fields and woodland. The North Hinksey Parish Character Assessment (January 2018) recognises that “the streets of North Hinksey Parish were laid out with generous provision for greenery in the public realm”. It goes on to describe as one of the Key Positive Features, the importance of Greenery in Residential Streets and quality of public green open space highlighting: “A number of large green spaces (including Raleigh Park, allotments and playing fields either side of Arnold’s Way provide access to green spaces that are fragments of the open space that characterised the area prior to the residential developments of the early 20th century onwards. [….] Pockets of woodland, formerly managed as coppice lie within and between the housing estates and on the edge of the suburb. They are now pockets of high biodiversity value habitat.” However, the report notes that Parish today is vulnerable to the loss of Green Character and the impairment of views to green space and the area’s rural setting. The October 2017 consultation event prompted comment from residents that greater recognition be given to the woodland areas between houses on the Elms Rise estate. To preserve the original green, spacious, semi-rural character, the green spaces and sites listed in Policy GS1 have been identified as of particular value. Policy GS2 covers all green spaces and their associated biodiversity and viewpoints. In line with the requirement to conserve biodiversity and provide a net gain in biodiversity through planning policy (Section 40 of the Natural Environment and Rural Communities Act 2006 and section 109 of the National Planning Policy Framework) developments and initiatives that actively increase biodiversity, enhance natural habitats and enrich the quality of green spaces will be encouraged and supported. Initiatives to maintain and increase the rural character of footpaths, bridleways and cycle-ways throughout the Parish will also be encouraged and supported. The objective of Policy GS3 is to enhance and protect from

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inappropriate development, the views and prospects of local, regional and national value or of special interest that contribute to the character of the local and wider landscape. This policy is accommodating of any form of development, built or vegetative, but requires that full consideration be given to the key views in terms of its position, design and scale, none of which should significantly detract from or obstruct the key views. The key views to and from our Parish contribute to defining both its character and that of the historic City of Oxford and have been categorized into three classes: Representative: views that may be glimpsed or have detracting features or be aspects that are typical of our Parish and may be seen elsewhere in the vicinity. Special: views including panoramic, elevated, long-distance vistas, affording an understanding of the Parish’s setting in the wider landscape. Exceptional: views include regionally valued long views across the skyline of the City of Oxford or capturing a quintessential rural village scene at the tranquil heart of North Hinksey. North Hinksey Parish lies adjacent to the historic city of Oxford, internationally renowned for its skyline as the city of “dreaming spires”. The City has initiated and implemented a planning methodology to define and protect the most significant and precious views across the city, using view cones that capture a sweep of landscape from a specific viewpoint. One such view cone lies within our Parish, in Raleigh Park.

The varied topography of the Parish creates a variety of vistas, from the low-rise residential roads in the valley at the northern side to the high hilltops that rise to the southern boundary. Our public consultations revealed that Parishioners place high value on a number of views within and without the Parish that are particularly distinctive to its character, location and context:

From Raleigh Park down to North Hinksey village & on towards Oxford From the corner of Sweetmans Road and Raleigh Park Road towards Oxford From the east side of the hill towards Osney Island and beyond towards Oxford From North Hinksey Lane towards the lines of trees along Seacourt Stream From Louie Memorial Fields over Port Meadow towards north Oxford and beyond From the east end of Chestnut Road north to the Botley Interchange, woods, Port Meadow and North Oxford From Hurst Rise Road towards Wytham Woods and the fields below From the north and west side of the hill towards Tilbury Farm and fields above it From Louie Memorial Fields west to Wytham

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and north to Seacourt Tower From St Paul’s Crescent north towards Wytham woods From the private road into Brookes Sport looking towards Cumnor Hurst and Boars Hill From Poplar Road looking over Elms Parade and up Elms Rise estate across the hillside From the Bridleway leading west from Harcourt Hill looking towards Hinksey Heights, Boars Hill and south-east Oxford beyond From North Hinksey Village Green north through the village

Appendix G, Map G.4 – remove VP11 unless further justification of its local importance can be provided.

4.7.1 Context and Community Feedback: The former Westminster College site on Harcourt Hill was taken over by Oxford Brookes University (OBU) on a 60-year lease in 2000. Up to that time the College had been used by the Methodist Trust to teach Education and Theology. OBU continued to use the campus for the same purposes and based part of their Departments of Education, History and Theology on the site. Gradually the Education Department has been decreasing in numbers as funding for teaching Education has changed with successive Government policies to the extent that it is no longer viable for the campus to be used primarily for that purpose. In 2012 OBU published a masterplan for development of the campus with the aim of having this adopted as a Supplementary Planning Document by the local planning authority. It became apparent once this document had been published that this plan had not been adequately consulted upon with the relevant authorities and stakeholders and was not considered 'fit for purpose'. Although not officially withdrawn the document was not pursued. Since that time OBU has undertaken a review of their estate and decided to close the campus at Wheatley and move the departments based there elsewhere. This process is ongoing and the transfer of the Business school from Wheatley to the Headington campus is due shortly occurred in September 2017 with the remaining faculties vacating by 2020. This has also led to a review by OBU of the location of various faculties and departments within their estate and they have expressed the desire to develop the facilities at Harcourt Hill. OBU objected to the various aspects of the Vale of White Horse District Council Local Plan 2031 which would inform and control the development of the site and they also pursued an amendment to the Local Plan to take the whole of the site out of the Green Belt. The Inspector for the Local Plan 2031 Part 1 has already made it known that he has decided against this removal. OBU have yet to make their final plans known. In the light of this uncertainty iIt is important that a viable plan of development is formulated for the campus that respects the location of the campus in the Oxford Green Belt, the local character of the surrounding area and addresses the issues associated with continues to address transport to and from the site.

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North Hinksey Parish Council and Harcourt Hill Estate Residents’ Association will continue to work with Oxford Brookes University to encourage a thriving campus experience which is a good place to live, study and teach. Development of Oxford Brookes University Harcourt Hill Campus including Brookes Sport should be in line with an agreed master plan compatible with the Vale of White Horse Local Plan 2031 Core Policy 9 that meets the University’s longer term needs for predominately educational uses in a manner that respects the Campus’s Green Belt setting and urban fringe context, and that sets a clear vision for the future of the site including the safeguarding of the green open spaces and the involvement with the local community in education, and the formation of links with the knowledge and leisure activities of the University. Public consultations throughout the Neighbourhood Plan process have consistently resulted in 90% plus support figures for the developing policy BU1, so although the text has been refined over time the bulk of the content has remained the same throughout much of the process. In particular a potential worsening of traffic issues related to any expansion of the Harcourt Hill Campus has been highlighted by Parishioners as the primary concern.

Policy BU1 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. iii) A Flood Risk assessment and Drainage Strategy to be prepared for the whole Campus to ensure that the scale of development proposed does not adversely impact on the local and wider network. (see NHPNP section 4.5 Utilities with regard to flooding and drainage)

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Development will be supported if: (a) It contributes towards sustainable modes of transport which access the Campus, does not increase the number of car parking spaces on the Harcourt Hill Campus site as a whole, and will not result in a significant* increase in student, staff and general public numbers travelling to the site is supported by a Travel Plan detailing the University’s current and future efforts to promote sustainable transport patterns. (b) For new housing or student accommodation on site, it can be demonstrated that these will only be used for students of staff of Oxford Brookes University, and will be predominantly (a minimum of 75% of the total housing units) for the use of staff and students principally assigned to work at this campus. *Significant being a 20% increase over the base line usage in 2010 as noted in the Oxford Brookes University Student numbers report December 2015.

Development will be encouraged to: (c) Have planning and design of architectural merit as in the VOWHDC Local Plan 2031 part 1 and the Vale of White Horse District Council Design Guide March 2015, with buildings appropriate to the location in line with the North Hinksey Parish Character Assessment (January 2018). (d) Keep any expansion of buildings within the present Green Belt boundaries and built footprint up area of the campus as identified in Map 4.1 (e) Utilise sustainable means of utilities and services including but not restricted to energy, waste and surface water (NHPNP Policy UT2)

Insert above as Map 4.1

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Leisure Provision Assessment

5.3 The facilities benefit from use by are highly reliant on members of the general public but it is unlikely the facilities would survive without the support and investment of the University. for financial viability, with the majority of users being general public from within 15 minutes drive of the site. Students and staff at Brookes make up less than 10% of total users and are the second smallest of five identified user groups.

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