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ITEM EX5 - ANNEX B

EXECUTIVE – 10 JUNE 2003

OXFORDSHIRE STRUCTURE PLAN REVIEW

Oxfordshire Structure Plan Review Deposit Draft –

Written Submission from Oxford City Council

Oxford City Council would like to support a number of key policies, to make some key points and to request a number of changes.

Overall

  1. Oxford’s Role – The Review describes the County as a City Region and it acknowledges that Oxford plays a central role in the economy of Oxfordshire (para 1.18). The County states, in the Review, that a priority is to support sustainable and inclusive economic growth (para 1.22 and Aim 4) in particular the development of the educational, scientific and technological economy. The County Council wants to see Oxford thrive (para 2.7). After 2011 the strategy also proposes that the focus for development should move towards the north-south corridor between Bicester, Oxford and Didcot, especially for transport investment (Para 2.10 and 2.17). The City Council supports all these statements.

  2. Yet the Plan, as written, is seriously flawed. It proposes that overall employment growth in Oxford should be restrained (para 2.8) and that over the long term Bicester should be the main growth location (para 2.18).

  3. This will have a very serious impact on the ability of the County to achieve its stated priority objective of sustainable development. The economy of the City will be seriously harmed, together with that of the County as a whole.

  4. The Oxford – Cambridge technology arc is a myth promoted by Milton Keynes because it wishes to raise its profile. A study into the Bioscience industries by the Oxford Economic Observatory indicates that the economy of Oxford and its immediate surrounds faces towards London, Heathrow and the Thames Valley corridor. In addition the high value sectors, where knowledge transfer and innovation is the key (para 6.16) want to be within or very close to Oxford itself.

  5. City Council’s request. The City agrees with a substantial part of the Review. In particular it agrees that sufficient land should be available in appropriate locations to reduce the need to travel (para 6.50). However the logic of this aim should be that land is found within the north-south corridor adjacent to the City itself for an urban extension. This would be the most sustainable location in the County.

  6. Request that paragraph 2.20 should be amended to promote a revision to the Green Belt and permit housing development as a southern extension to the City, south of Grenoble Road, in a comparable way to the proposals for a new community at Begbroke-Kidlington-Yarnton.

  7. The City Council agrees that Oxford should not grow unchecked (para 2.8). However, it requests that there should be no restraint upon the use of its current major employment sites for continued employment use, together with securing the exciting urban renaissance of the West End of the City for a wide-range of mixed uses including new employment. Without this, the economy of the City would be harmed and potential high-value sector employment would be lost to elsewhere within the South East region or to Europe. This point is expanded upon below.

    8. Transport

  8. General point – The Review needs to make a better and more obvious link between its land use strategy and transport objectives.

  9. Constraint on development - The level and location of development in the County should not be unnecessarily constrained by the lack of improvements to existing infrastructure. The County can target and focus highway improvements to address strategic network weaknesses and growth areas.

  10. Request that Policy T8 and the supporting text should indicate that improvements can and will be made to the existing infrastructure over time.

  11. Paragraphs 2.24 and 2.27 – The acknowledgement in ‘Implementing the Strategy’ that this will require close working with the Districts and revisions to the Local Transport Plan is supported.

  12. Paragraph 4.9 – Request adding text to this paragraph that would support the development of a transport strategy for all of Oxford City, as this would better inform what type of highway contributions need to be secured via S106 agreements.

  13. Paragraph 4.10 – Request adding text to make it clear that parking standards in Oxford City are different to those in the rest of the County due to good and accessible alternative modes of transport.

    14. Economy

  14. Paragraph 2.8 – It states that ‘employment in the city will continue to be restrained …Land is however available within the city to support the development of employment sectors that need to be located there.’

  15. The City Council is not sure what the above assumption is based on but this is contrary to the views of key employers in Oxford who have made objections to the Second Draft Deposit Local Plan 2001-2016. The report ‘Enterprising Oxford’ by Oxfordshire Economic Observatory highlights the growth of Oxfordshire’s high-tech economy. It makes clear that Oxfordshire cannot standstill and should support ‘smart development’ in order to achieve sustainable development. For example, ‘planning policies have been unduly restrictive of high-tech activity associated with university and other research institutions in Central Oxfordshire.’

  16. The County and City Councils are working together on the urban renaissance of the West End of the City, together with the possible relocation of the station. This will bring significant benefits to both the City and the County as a whole and will make an important contribution to the County’s transport objectives. However, it is important that the Review does not communicate the wrong messages about the future economy of the City. The use of phrases such as ‘restraint on employment’ and ‘encouraging development to locate outside the City’ could be very damaging to this exciting project.

  17. Notwithstanding this, it should be understood that the City Council does not want unlimited employment growth or to promote a strategy that would harm the physical environment of the City or create social exclusion.

  18. Paragraphs 6.4 & 6.6 – County Council wants to build on Oxfordshire’s employment strengths and allow for expansion of local firms, especially research and development. Yet Policy E1 specifically promotes employment land in Oxford City to be redeveloped for housing.

  19. Employment restraint - Key employers in Oxford City have argued that they will not remain competitive and successful if opportunities continue to be excessively restrained. If the employment levels below continue then it is far from clear to see how this will support key employment sectors and lead to sustainable employment in Oxford City up to 2016.

    20. Oxfordshire District Councils Employment Levels 1995-2001

    Cherwell

    + 38%

    16,500 jobs

    Oxford City

    + 1.7%

    735 jobs

    South Oxon

    + 29%

    12,590 jobs

    Vale of White Horse

    + 15%

    6,740 jobs

    West Oxon

    + 15%

    6,670 jobs

    Source: Annual Business Inquiry Employee Analysis 1995/2001

  20. Policy E1 – Request deleting the second paragraph in the policy. A measure of restraint will still be achieved by limiting employment to existing and allocated sites, including those in the West End. Also this part of the Policy repeats points unnecessarily about small firms.

  21. The land supply in Oxford City is tightly constrained and therefore there is competition already from a range of land uses. Whilst the City Council recognises the need for more housing, especially affordable and key worker housing, this policy leaves no room for other important uses, such as community facilities, primary care facilities, and nurseries (i.e. preference for residential use will increase land values to such an extent that it will exclude all other land uses). This means in reality that achieving mixed use developments on ‘windfall employment’ sites will be very difficult.

  22. The County proposal to prescribe in the Review residential use over all other land is not accepted. It is for the Oxford Local Plan to be the determinant of land uses.

    23. Housing

  23. Policy H1 – The City Council will need more time to consider whether the housing figure allocated in the Review for Oxford of 5,500 additional dwellings is appropriate.

  24. Policy H1 and paragraph 7.4 – state that ‘At least 55% of all new dwellings should be built on previously developed land within urban areas …’ Oxford City, over the last three years, has almost achieved 100% of additional housing on previously developed land. The Government’s policy and RPG9 target is 60% of all new housing to be on previously developed land.

  25. Request the County seriously think about raising the figure in Policy H1 to at least 60%.

  26. Policy H4 – This policy on affordable housing is welcomed and supported. Request that the County give further thought, however, in the text to make it clear that there are separate needs for affordable housing and key workers. If these two categories are lumped together then developers are likely to favour providing for key workers at the cost of people in greater housing need. The issue of equity and prioritising types of housing need is vital, especially in Oxford City where the land supply is so limited.

Paper prepared by Michael Crofton Briggs, Chief Planning Officer, Oxford City Council.

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