Agenda Item No. 8 WEST OXFORDSHIRE DISTRICT COUNCIL CABINET: WEDNESDAY 13 FEBRUARY 2019 SOUTH OXFORDSHIRE LOCAL PLAN REPORT OF THE HEAD OF PLANNING AND STRATEGIC HOUSING (Contact: Chris Hargraves, Tel: (01993) 861686) (The Cabinet’s decision on this matter will be a resolution) 1. PURPOSE To consider and respond to South Oxfordshire’s Proposed Submission Draft Local Plan (2011 – 2034). 2. RECOMMENDATION That the contents of the report be noted and that the comments attached in the Appendix are submitted to South Oxfordshire District Council by way of a response. 3. BACKGROUND 3.1. South Oxfordshire District Council is in the process of preparing a new Local Plan which, once adopted, will replace a number of ‘saved’ policies from the previous Local Plan 2006 and Core Strategy 2012. 3.2. Following various public consultations held between 2014 and 2017, the Council published a proposed submission draft version of the new Local Plan in October 2017. 3.3. However, in light of the representations received, at a meeting of Full Council in May 2018, the decision was taken to re-assess all of the main sites in the District that are capable of forming a strategic allocation, with a view to informing an updated version of the plan for public consultation. 3.4. That review has now been completed and on 20 December 2018, Councillors voted to approve the South Oxfordshire Local Plan and it has now been formally published for a statutory 6-week period of consultation from 7 January – 18 February 2019. 4. SOUTH OXFORDSHIRE LOCAL PLAN – MAIN CHANGES 4.1. The previous version of the Local Plan (October 2017) was based on the following elements:  A plan period running from 2011 – 2033.  A total housing requirement of 20,800 homes comprising 17,050 homes for South Oxfordshire’s own housing needs (775 per year) and a further 3,750 homes for Oxford’s ‘unmet’ housing needs (but not identified at any one site or location).  Planned provision of 22,563 homes (i.e. above the identified requirement) to provide a degree of flexibility and allow for changing circumstances.  35.9 hectares of employment land to support planned economic growth.  Focusing major new development in Science Vale including Didcot Garden Town and Culham (noting that much of the proposed development at Didcot Garden

Item No. 8, Page 1 of 11 Town – around 6,500 homes was already completed or committed through the previous 2012 Core Strategy).  Strategic growth at four new locations connecting through the central area of the District at Berinsfield (1,700 homes) Chalgrove (3,000 homes) land adjacent to Culham Science Centre (3,500 homes) and Wheatley (300 homes).  Supporting the roles of Henley-on-Thames, Thame and Wallingford including housing allocations to be made through Neighbourhood Plans (c. 1,100 homes).  Supporting and enhancing the roles of the larger villages including Benson, Berinsfield, Chalgrove, Chinnor, Cholsey, Crowmarsh Gifford, Goring on Thames, Nettlebed, Sonning Common, Watlington, Wheatley and Woodcote as local service centres, including housing allocations to be made through Neighbourhood Plans (c. 1,050 homes).  Supporting smaller and other villages by allowing limited amounts of housing and employment (c. 500 homes).  A range of other policies relating to housing type and mix including affordable housing, the economy, infrastructure, the natural and historic environment, the built environment, town centres and shopping and community and recreational facilities. 4.2. In response to the draft plan, South Oxfordshire District Council received a large number of responses including a joint response from West Oxfordshire District Council, Cherwell District Council and Oxford City Council. 4.3. The joint response raised a number of specific concerns including:  South Oxfordshire’s departure from the agreed Growth Board apportionment for Oxford’s unmet housing requirement (i.e. planning for 3,750 homes instead of 4,950) and the consequent failure of the Council to discharge the Duty to Cooperate.  Concern regarding the additional pressures being placed on the other Oxfordshire local authorities as a result of the above.  The failure to prepare a strategy within the plan which recognises the importance of considering the relationship of sites to Oxford when considering how well they contribute to helping to meet Oxford’s needs.  Concern about the lack of clarity and specificity regarding which particular housing sites are intended to form South Oxfordshire’s contribution towards the unmet need.  The failure to prepare a plan which effectively contributes to Oxford’s unmet affordable housing need element of the apportionment given the low percentage of affordable housing that will be sought on sites brought forward through the plan.  Specific concerns that none of the strategic site allocations at Chalgrove Airfield, Culham and Berinsfield provide sustainable locations for accommodating housing needs for Oxford with no consideration having been given to their spatial relationship or connectivity to Oxford.  The fact that other reasonable options for accommodating Oxford’s unmet housing needs not properly considered including sites which surround the City’s administrative boundary such as Grenoble Road, Wick Farm and Northfield.

Item No. 8, Page 2 of 11 4.4. In light of this and other representations received, South Oxfordshire District Council agreed in May 2018 to review their Local Plan including a reassessment of all available housing sites. 4.5. This process took place during the second half of 2018 and the Council has now published a revised version of the plan with comments invited up until 18 February 2019. 4.6. Comments made at this stage will be submitted to Government by the end of March 2019 together with the plan and supporting evidence base. Examination hearing sessions are then anticipated to take place in the summer. 5. OVERVIEW OF MAIN PLAN CHANGES 5.1. The structure of the draft Local Plan remains largely unchanged as does the overall vision and strategic objectives. The roll forward to 2034 is also a minor issue and is simply intended to ensure a 15-year plan period from the anticipated date of adoption. 5.2. However, there are a number of more significant changes that have been made which importantly, address the concerns which were raised in the previous response submitted jointly by West Oxfordshire District Council, Cherwell District Council and Oxford City Council. 5.3. The main changes are outlined below and should be read in conjunction with the suggested consultation response attached in the Appendix. Overall Spatial Strategy (Policy STRAT1) 5.4. Whilst Science Vale including Didcot Garden Town remains a key focus for growth, instead of complementing this with growth at four strategic locations in a central belt across the District, the spatial strategy now seeks to provide a sustainable pattern of development throughout the District including seven strategic allocations at Grenoble Road, Culham, Berinsfield, Chalgrove, Wheatley, Northfield and North of Bayswater Brook. 5.5. Importantly, the strategy also makes an explicit commitment to meeting the unmet housing needs of Oxford City ‘on strategic allocations adjacent to the boundary of Oxford near to where that need arises’. 5.6. The strategy also places an increased emphasis on close working with partner agencies, neighbouring local authorities, communities and other stakeholders to ensure the timely delivery of the strategy. Commentary/response 5.7. The changes made to the overall strategy are significant and help to address the concerns raised by West Oxfordshire District Council at the previous consultation stage in 2017. 5.8. In particular, the strategy makes explicit provision for meeting Oxford’s unmet housing need on three new strategic allocations adjacent to Oxford. This has addressed a key aspect of West Oxfordshire’s previous objection and is therefore to be supported. 5.9. The additional commitment to partnership working including with adjoining local authorities is also supported.

Item No. 8, Page 3 of 11 Housing and Employment Requirements (Policy STRAT2) 5.10. In terms of housing provision, the revised plan continues to identify a requirement of 775 homes per year for South Oxfordshire which is in line with the Oxfordshire SHMA 2014 but has been rolled forward on a pro-rata basis to 2034 i.e. a total requirement of 17,825 homes (previously 17,050). 5.11. In addition, the plan now seeks to deliver a further 4,950 homes for Oxford’s unmet need between 1 April 2021 and 31 March 2031 (i.e. 495 homes per year). 5.12. The total housing requirement is therefore 22,775 (previously 20,800). 5.13. In terms of employment land, the level of planned provision has increased slightly from 35.9 hectares to 37.5 hectares to reflect the roll forward of the plan period to 2034. Commentary/response 5.14. The figure of 775 homes per year for South Oxfordshire’s own housing need is consistent with the recommendations of the Oxfordshire SHMA (2014) which remains the most up to date assessment of housing need for Oxfordshire. 5.15. Because the draft Local Plan runs to 2034 it has been necessary to roll the requirement forward on a pro-rata basis. In the absence of any alternative evidence of housing need, this approach is reasonable and is to be supported. 5.16. Importantly, the draft plan now makes provision for an additional 4,950 homes to help meet Oxford’s identified housing needs. This level of provision is consistent with the apportionment agreed by the Oxfordshire Growth Board in September 2016 is therefore in accordance with the Duty to Cooperate and is also to be supported. 5.17. The proposed level of employment land provision appears to be evidence based and raises no particular concerns. It will of course be for South Oxfordshire to justify their approach through the examination process. Housing Density (Policy STRAT5) 5.18. This is a new policy that seeks to ensure certain minimum net densities for major residential developments based on their location in the District. This is consistent with the NPPF which requires consideration to be given to the efficient use of land. 5.19. The Council’s previous Core Strategy (2012) included a density policy based on 25 dwellings per hectare but research undertaken by the Council has demonstrated that the Local Plan should be requiring higher densities in South Oxfordshire. 5.20. The new Local Plan therefore requires higher densities (50-70 dwellings per hectare) where there are sustainable transport opportunities with lower densities (35-45 dwellings per hectare) in other locations. Commentary/response 5.21. The policy is consistent with the NPPF and is underpinned by separate research and analysis to justify the approach taken. Consideration of the efficient use of land is also required to justify the release of land from the Green Belt as proposed elsewhere in the Local Plan. 5.22. As such, it is to be supported insofar as it will not only help to ensure the most efficient use of land is made in the most accessible, sustainable locations but to also support the case for the release of development sites on the edge of Oxford within the Green Belt

Item No. 8, Page 4 of 11 to help meet Oxford’s identified housing needs. However, it is considered important to make the point that higher densities should not be achieved at the expense of quality of place making and the amenity of those living there. Green Belt (Policy STRAT6) 5.23. This policy is similar to that which was previously published but has been updated slightly in line with national policy and also to take account of the three additional development sites which are now proposed to be released from the Green Belt (Grenoble Road, Northfield and North of Bayswater Brook). Commentary/response 5.24. The release of land from the Green Belt for development requires careful consideration with boundaries to only be altered where exceptional circumstances are fully evidenced and justified through the preparation or updating of plans. 5.25. Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, local authorities should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. 5.26. It will be for South Oxfordshire District Council to demonstrate that exceptional circumstances exist but as a matter of general principle, it is self-evident that if provision is to be made for Oxford’s unmet needs on sites close to the edge of Oxford, then some development within the Green Belt is inevitable. 5.27. As such, the general premise of Policy STRAT6 is supported. Strategic Allocations (Policies STRAT7, 9, 10, 11, 12, 13 and 14) 5.28. As outlined above, the updated plan includes seven strategic housing allocations (previously just four). The seven sites are as follows: Site Total capacity Number of homes expected to be delivered by 2034 Land at Chalgrove Airfield 3,000 homes plus 5 ha of 2,025 employment land Land adjacent to Culham 3,500 plus at least 7.3 ha of 1,850 Science Centre employment land Land at Berinsfield 1,700 1,600 Land south of Grenoble 3,000 plus around 10 ha of 1,700 Road employment land and extension of park and ride Land at Northfield 1,800 1,800 Land north of Bayswater 1,100 1,100 Brook Land at Wheatley Campus 300 300 Totals 14,400 10,375

Item No. 8, Page 5 of 11 5.29. The total capacity of the sites is anticipated to be 14,400 but the plan assumes that only a proportion of these (10,375 homes) will be able to be delivered by the end of the plan period - 2034. 5.30. Three of the sites (Grenoble Road, Northfield and Bayswater Brook) are new allocations and have been included to provide more specificity regarding the delivery of Oxford’s unmet housing needs. 5.31. All three sites are located within the Oxford Green Belt but importantly, are in sustainable locations adjacent to the edge of Oxford and are thus well placed spatially to assist with delivering the City’s housing needs. 5.32. As outlined above, exceptional circumstances must be demonstrated to justify the release of land for the Green Belt and the plan sets out what South Oxfordshire District Council considers those circumstances to be for each site. 5.33. It is relevant to note that the three sites were considered through the joint-work led by the Oxfordshire Growth Board in 2016 and performed well when assessed against the agreed criteria, primarily due to their strong spatial relationship to Oxford. Commentary/response 5.34. In its previous response to South Oxfordshire’s earlier draft plan, the District Council raised specific concerns regarding the lack of specificity regarding which allocated sites would contribute towards Oxford’s housing need (both market and affordable housing). 5.35. It also raised concerns that a number of sustainable development opportunities on the edge of Oxford had not been included in the plan. 5.36. The revised plan addresses both of these key points and is therefore to be supported. In particular, the plan makes it explicit which sites are intended to contribute to Oxford’s housing need and which are intended for South Oxfordshire’s own housing need. 5.37. Furthermore, the three new sites included on the edge of Oxford all performed well when assessed jointly in 2016 and whilst located in the Green Belt, are to be supported in principle by virtue of their proximity and strong relationship to Oxford. Other Housing Delivery/Sites 5.38. In addition to the seven strategic sites outlined above, the revised plan makes provision for new housing to come forward in a number of other locations including through existing commitments, neighbourhood plans, three small allocations at Nettlebed and anticipated windfall. The achieved/expected delivery is summarised in the table below. Source Net number of dwellings to 2034 Completions 4,364 Commitments (as of 30 April 2018) 11,362 Strategic allocations 10,375 Market Town allocations to be made 519 through Neighbourhood Plans Larger village allocations to be made 499 through Neighbourhood Plans

Item No. 8, Page 6 of 11 Source Net number of dwellings to 2034 Nettlebed allocations 46 Windfall 1,300 Total 28,465

5.39. Total achieved/expected supply in the plan period is thus 28,465 (with more homes anticipated to follow on the strategic sites beyond 2034). Commentary/response 5.40. The revised plan anticipates delivery of around 28,465 homes in the period 2011 – 2034 with a further 4,025 homes to come forward beyond then on a number of strategic sites. 5.41. As set out previously, the identified housing requirement is 22,775 homes meaning that the plan is effectively ‘over-providing’ in terms of the number of homes expected to come forward. 5.42. This will be a matter for the South Oxfordshire Local Plan Inspector to consider but in principle, there is clearly merit in building in an additional ‘buffer’ to take account of any potential slippage and/or change in circumstances. 5.43. The level of anticipated supply will also make a valuable contribution towards the commitments set out in the Oxfordshire Housing and Growth Deal and is therefore to be supported. Affordable Housing (Policy H9) 5.44. This policy sets out the circumstances in which affordable housing will be sought on new developments. It is similar to the approach set out in the West Oxfordshire Local Plan with on-site affordable housing being sought on larger developments of 10 or more dwellings outside the AONB with a financial contribution sought from smaller schemes of 5 – 10 dwellings within the AONB. 5.45. For on-site provision, the requirement across most of the District is 40% affordable housing, but notably, in respect of the three strategic allocations adjacent to Oxford, the requirement has been increased to 50% in line with the policy requirements set out in the Oxford City Core Strategy and emerging draft Local Plan. Commentary/response 5.46. One of the key issues raised by the District Council in its previous representation was the fact that the original draft plan failed to effectively contribute towards Oxford’s unmet affordable housing need. 5.47. The revised approach set out in Policy H9 addresses this concern by increasing the requirement from 40% to 50% on the three allocated sites adjoining Oxford. This approach is therefore to be supported. Other Policies 5.48. The revised plan includes a large number of other policies on a variety of issues including housing mix, self-build, specialist housing, employment, tourism, infrastructure, the environment, design, town centres and community facilities.

Item No. 8, Page 7 of 11 5.49. It is relevant to note that the plan now includes a new policy which sets out South Oxfordshire’s commitment to working with Network Rail, Highways England, the National Infrastructure Commission, the County Council and others to plan for, and understand the impacts of changes to rail infrastructure and service improvements linked to East-West rail and to plan for, and understand impacts and required mitigation associated with the Oxford to Cambridge Expressway. 5.50. Having reviewed these various other policies, they appear to raise no particular concerns and are therefore to be supported in principle. Overall Conclusions 5.51. Whilst the structure and overall content of the South Oxfordshire draft Local Plan remain similar to that previously published, a number of important changes have been introduced including an increase in the number of new homes to be provided in respect of Oxford’s unmet housing need and the inclusion of three strategic allocations on the edge of Oxford to meet that need in a measurable, site specific manner. 5.52. The changes address the concerns raised previously by West Oxfordshire District Council jointly with Cherwell and Oxford and are therefore to be supported in principle. 5.53. Attached in the Appendix is a suggested letter of response to the consultation which expands on the points set out in this report. Subject to the approval of Cabinet, the suggested consultation response will be sent to South Oxfordshire District Council and will subsequently be submitted to their Local Plan Inspector. 6. FINANCIAL IMPLICATIONS The report raises no direct financial implications. 7. RISKS Not submitting a response to the consultation would mean there is a risk of West Oxfordshire District Council not being able to put its view to the appointed Planning Inspector including participation in any examination hearing sessions. 8. REASONS South Oxfordshire District Council has formally published its proposed submission draft Local Plan covering the period 2011 – 2034 and it is important that West Oxfordshire District Council takes the opportunity to comment at this stage having regard to the Duty to Co- operate with adjoining local authorities.

Giles Hughes Head of Planning and Strategic Housing (Author: Chris Hargraves, Tel: (01993) 861686; EMail: [email protected]) Date: 30 January 2019 Background Papers: South Oxfordshire Proposed Submission Draft Local Plan (2011 – 2034) – see http://www.southoxon.gov.uk/ccm/support/dynamic_serve.jsp?ID=999354812&CODE=22D6A357 E421757B45F1ABF8605F94B5

Item No. 8, Page 8 of 11 Appendix Proposed Response to Consultation Dear Sir/Madam Submission draft South Oxfordshire Local Plan (2011 – 2034) Thank you for the opportunity to comment on the proposed submission draft South Oxfordshire Local Plan. West Oxfordshire District Council welcomes the decision made to review the plan and the positive steps taken by South Oxfordshire to address the concerns we raised previously in 2017, in particular the level of housing provision to be made in respect of Oxford’s unmet housing needs and the manner in which this is delivered. On this basis, we consider the Duty to Cooperate to have been met. Set out below are a number of comments on various aspects of the revised draft plan. As you will see these are supportive of the changes proposed and hopefully self-explanatory but if you do need any further clarification please let me know. Overall Spatial Strategy (Policy STRAT1) The changes made to the overall strategy are significant and help to address the concerns raised by West Oxfordshire District Council at the previous consultation stage in 2017. The allocation of seven strategic sites as proposed will make a significant contribution towards meeting identified housing needs in the period to 2034 and beyond and they are therefore supported in principle (see further comments below). We particularly support the explicit reference which is now made in the policy to meeting Oxford’s unmet housing need on strategic allocations adjacent to the boundary of Oxford near to where that need arises. The proposed sites have a strong spatial relationship to Oxford and are thus logical locations to assist in delivering Oxford’s unmet housing need. This has addressed a key aspect of West Oxfordshire’s previous objection. Also supported is the additional commitment made in the policy to partnership working including with adjoining local authorities. West Oxfordshire District Council welcomes the opportunity for further continued dialogue in relation to the delivery of the spatial strategy. Housing and Employment Requirements (Policy STRAT2) The identified housing requirement for South Oxfordshire at 775 homes per year is consistent with the Oxfordshire Strategic Housing Market Assessment (2014) which remains the most up to date assessment of housing need for the Oxfordshire Housing Market Area. The SHMA relates to the period 2011 – 2034 and the per annum requirement has been rolled forward on a pro-rata basis to 2034 to tie in with the end of the plan period. In the absence of any alternative assessment of housing need to 2034 this approach is considered reasonable and is therefore supported in principle. In addition to South Oxfordshire’s housing need, the policy also recognises the requirement to provide a further 4,950 homes as a contribution to Oxford’s unmet housing need. This is consistent with the apportionment agreed by the Oxfordshire Growth Board in September 2016, in accordance with the Duty to Cooperate and is therefore supported.

Item No. 8, Page 9 of 11 The policy states that this additional provision will be delivered in the period 1st April 2021 – 31 March 2031 i.e. 495 homes per year. This is consistent with the approach which was agreed by the Oxfordshire Growth Board in September 2016 and subsequently reflected in the West Oxfordshire Local Plan. It is therefore supported. We note the intended level of employment land provision at 37.5 hectares which will clearly help to meet the projected increase in job numbers in the District and is also therefore supported in principle. Housing Density (Policy STRAT5) This new policy is supported in principle. Whilst we have not reviewed in detail the underpinning evidence and analysis, the basic premise of promoting higher densities in the most sustainable, accessible locations is sensible and consistent with national policy. The approach taken also supports the Council’s decision to remove some land from the Green Belt in order to facilitate development. It is essential however that the pursuit of higher densities is not achieved at the expense of quality place making and residential amenity. It will therefore be important through the application of this and other local plan policies e.g. on design, to ensure that the higher density developments coming forward are not characterised by inadequate indoor and outdoor space, excessive on-street parking and other issues that are sometimes apparent in higher density schemes. Green Belt (Policy STRAT6) It will be for South Oxfordshire District Council to demonstrate that exceptional circumstances exist but as a matter of general principle, it is self-evident that if provision is to be made for Oxford’s unmet needs on sites close to the edge of Oxford, then some development within the Green Belt is inevitable. As such, the general premise of Policy STRAT6 is supported in principle. Strategic Allocations (Policies STRAT7, 9, 10, 11, 12, 13 and 14) In its previous response to South Oxfordshire’s earlier draft plan, the District Council raised specific concerns regarding the lack of specificity regarding which allocated sites would contribute towards Oxford’s housing need (both market and affordable housing). It also raised concerns that a number of sustainable development opportunities on the edge of Oxford had not been included in the plan. The revised plan addresses both of these key points and is therefore supported. In particular, the plan makes it explicit which sites are intended to contribute to Oxford’s housing need and which are intended for South Oxfordshire’s own housing need. The three new sites included on the edge of Oxford (STRAT 11, 12 and 13) all performed well when assessed jointly through the Growth Board work in 2016 and whilst located in the Green Belt, are supported in principle by virtue of their proximity and strong relationship to Oxford. Anticipated Housing Delivery from Other Sources (Policies H1, H2, H3, H4, H5, H6, H7 and H8) We note that the revised plan anticipates delivery of around 28,465 homes in the period 2011 – 2034 with a further 4,025 homes to come forward beyond then on a number of strategic sites. The identified housing requirement is 22,775 homes meaning that the plan is effectively ‘over- providing’ in terms of the number of homes expected to come forward.

Item No. 8, Page 10 of 11 This will clearly be a matter for the appointed Local Plan Inspector to consider but in principle, there is clearly merit in building in an additional ‘buffer’ to take account of any potential slippage and/or change in circumstances. The level of anticipated supply will also make a valuable contribution towards the commitments set out in the Oxfordshire Housing and Growth Deal and is therefore supported. Affordable Housing (Policy H9) One of the key issues raised by the District Council in its previous representation was the fact that the original draft plan failed to effectively contribute towards Oxford’s unmet affordable housing need. The revised approach set out in Policy H9 addresses this concern by increasing the requirement from 40% to 50% on the three allocated sites adjoining Oxford. This approach is therefore supported. Other Policies We note that the revised plan includes a large number of policies on various topics and issues and having reviewed these, they raise no particular concerns and the policies are thus supported in principle including in particular the commitment made to partnership working in respect of east- west rail and the Oxford to Cambridge Expressway under Policy TRANS1a. I trust the comments set out above are helpful but if you do need additional information or further clarification on any of the matters raised, please let me know. Yours faithfully

Chris Hargraves Planning Policy Manager West Oxfordshire District Council

Item No. 8, Page 11 of 11