Comments on Draft West Oxfordshire’s Core Strategy
The City Council welcome the opportunity to comment on the Draft
West Oxfordshire Core Strategy; and would therefore wish to make the
following points:
Key assumptions
Firstly there do appear to be key assumptions that underpin the
strategy towards growth in West Oxford. These seem to rely on the
limited capacity of West Oxfordshire to sustainably accommodate
further significant growth together with the inadequacy of the existing
infrastructure. Since these are important ‘planks’ that set the framework
for the housing and employment growth strategy, it would be useful at
the outset of the Core Strategy to summarise the main elements of the
background evidence base, which support this policy approach.
The Core Strategy recognises that the key challenges that West
Oxfordshire face are the need for additional housing generally; the
need for affordable housing; and the need for further employment
land. The strategy for providing new housing need appears to rely on
population growth that is based on ‘natural’ growth forecast scenarios
(Oxfordshire Population and household forecasts, undertaken by
Greater London Authority). This approach does not however appear to
take into account the future population growth through migration that
will add to the demand for housing from those living outside the District.
In a desirable area such as West Oxfordshire where people wish to live
and indeed retire to, this could represent a significant additional
proportion of people.
This evidence suggests that there will be a significant increase in
population growth, whereas the scale of housing provision in the Core
Strategy appears to be minimal. Even these forecasts do not appear to
estimate the full extent of the population growth that will take place,
which is greater than the ‘natural’ growth. This approach to forecasting
views West Oxfordshire, in isolation from the natural movement of
people between neighbouring Districts and indeed from areas outside
the County boundaries.
The Oxfordshire Population and household forecasts published in July
2010, produced by Oxfordshire County Council, provides the most
recent estimates. These show that the population growth is forecast to
continue across all Oxfordshire Districts between 2006 - 2026. Whilst the
greatest increase (17.5%) will be expected to take place in the Vale of
White Horse (through planned developments in Didcot, Wantage and
Grove) is not surprising; it is interesting to note that West Oxfordshire has
the second highest expected change in the County with a forecast
increase of 16.6%. This compares with only 11.3% in Oxford.
Housing strategy
The policy approach on new residential development does seem to
rely on meeting a ‘local’ housing need that does not fully reflect the
sub-regional context. Indeed the need for housing generally within the
sub-regional area is significant and is only likely to be met in the future
with a co-ordinated approach among Districts with each meeting a
proportion of the growth. In the absence of the Regional Spatial
Strategies (RSS’s) soon to be formally abolished, the only framework for
considering the implications of meeting forecast housing demand at
the wider sub-regional level will be through the newly formed
Oxfordshire City Region LEP. Whilst this organisation is at the early stages
planning and housing growth are intended to be key strategic issues,
which will be discussed between the County, District representatives
and the business community. It would therefore be helpful if the Core
Strategy made reference to this wider spatial setting, which will be of
greater significance in the future, particularly given the longer time
period for this plan.
The Core Strategy sub-divides West Oxfordshire into five areas, which
serves to illustrate how over time each area will change. But the overall
amount and distribution of housing shows that with a forecast
requirement of 4,300 homes and 1,200 already committed there is only
a modest requirement of 3,100 new homes planned to 2027. This is
significantly less than the South East Plan target of 7,300 homes, and
therefore potentially places added pressure on neighbouring district
authorities to meet future housing need.
West Oxfordshire is characterised by high house prices; few social
rented properties; and a significant projected increase in older people.
These represent some of the key challenges for the Core Strategy to
address. It is not however clear from the spatial strategy whether the
policies that are proposed will be able to fully address the scale and
nature of the increase in population, including migration, that will need
further housing which is affordable and able to meet this demand.
In this context it is therefore surprising that the policy on the retention of
existing housing is not stricter. The loss of the existing housing stock
would probably benefit from being strictly safeguarded and only
accepted in exceptional circumstances.
Employment strategy
The employment strategy is based on an Employment Land Review,
which considers a range of scenarios. The Preferred approach
suggested by the consultants is Scenario 1: Steady Growth (Business as
Usual). The strategy now being proposed appears to be more akin to
Scenario 3: Indigenous growth (constrained growth), which allocates
little additional land but relies to a large extent on the existing land
supply.
This policy approach with few new sites coming forward does not
promote sustainable economic prosperity for West Oxfordshire and is
therefore unlikely to meet one of its key objectives to promote a
greater level of self-containment for its local economy. It could
potentially have two particular impacts which would be significant for
neighbouring authorities. Firstly it would potentially increase the need
for further employment land to be provided in other Districts, such as
Oxford. Secondly there is a considerable amount of in-commuting from
the rural areas, such as West Oxfordshire to the main centres of
employment, such as Oxford. By limiting employment opportunities the
Core Strategy will not make a significant contribution to reducing incommuting.