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.