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ITEM EX7

EXECUTIVE – 16 MARCH 2004

OXFORDSHIRE STRUCTURE PLAN 2016 DEPOSIT DRAFT – CONSULTATION RESPONSES

Report by Head of Sustainable Development

Introduction

  1. The draft Oxfordshire Structure Plan 2016 was placed on deposit on 26 September 2003 for six weeks for consultation. The purpose of this report is to set out the key issues raised by the consultation responses, consider whether any changes should be made to the plan before the Examination in Public (EIP), and explain arrangements for the EIP.

    (Alternative Minerals Areas in South Oxfordshire - plan (download as .doc file))

    2. The Consultation Process

  2. The draft Plan was placed in public libraries, County and district council offices, and one stop shops. Summary leaflets were also available in these places and in doctors’ and dentists’ surgeries and community, information and advice centres. Copies of the draft Plan were sent to all town and parish councils and over 350 consultees, and were available to purchase or download free of charge from the County Council’s web site. An online response form was available – the first time this type of facility has been used by the County Council. A series of five public meetings were held early in the consultation period, one in each district. Meetings were also held with local stakeholders, businesses and district council members. The closing date for making comments was 7 November 2003.

    3. Responses to the Deposit Draft Plan

  3. Copies of all submissions received by the closing date and a summary of all the objections and representations have been placed in the Members’ Resource Centre. Summaries of key points raised on each topic area are set out in Annex A (download as .rtf file) to this report.

  4. Just over 2680 individuals and organisations made comments on the draft Plan, of whom about 350 respondents used the online response form. The number of responses is the largest received on a draft Structure Plan in Oxfordshire. Most of the objections were about two major issues – the proposed development in the Green Belt south of Oxford; and the proposed new strategic area for sand and gravel extraction in South Oxfordshire. Other major areas of comment were on other aspects of the development strategy and housing distribution, the economy, transport and affordable housing.

  5. At this stage, the County Council could suggest changes to the Plan to meet particular objections before the EIP commences. It is recommended (but is not a statutory requirement) that any such changes should be published to give the opportunity for those who disagree with the changes to comment. Any comments would go forward for consideration at the EIP.

  6. The key issues raised in the consultation responses are discussed below. In addition there have been a number of more detailed comments made about the wording of specific policies and the text in the draft Plan. Because of the large number of responses it has not been possible in the time available to identify detailed changes in response to all objections. However, it is not necessary for the County Council to respond to all objections at this stage. The County Council will have to respond to all objections to the policies when it considers whether to propose modifications to the Plan in the light of the Panel report on the EIP.

  7. In preparing for the EIP it is recommended that agreement of any detailed changes that might be identified be delegated to the Head of Sustainable Development in consultation with the Executive members for Sustainable Development, and Transport as changes which the County Council might be prepared to accept.

  8. Comments on the supporting text (which explains and amplifies the policies in the plan, but is not part of it) can be taken into account when the text is amended to reflect any modifications made to the plan after the EIP. Therefore with the exception of comments made on the proposed strategy post 2016, comments on the supporting text are not considered in the remainder of this report.

    9. Strategy and housing distribution

  9. GOSE and SEERA support the overall level of housing which accords with Regional Planning Guidance (RPG9). However, some respondents, mainly developers, consider that the figure should be increased in light of the overall shortage of housing in the South East and because they think the housing provision will increase in the review of RPG9. Except for South Oxfordshire District Council, the district councils have generally not objected to the overall amount of housing for their districts.

  10. The Highways Agency have expressed their concerns that high traffic growth on the A34 and at junctions has already compromised the route’s safe and efficient operation. The Agency regards A34 as a "most strategic route", to which access may need to be restricted to protect its strategic function, and warn that the Structure Plan should not rely upon improvements to the route, as it is unlikely that any could be delivered during the plan period, up to 2016. Since development in any major urban area in the county would have some effect in generating traffic on the A34 the inconsistency between this position and the Government’s requirements for development has been taken up by officers in particular with GOSE. The Agency do not wish to oppose the proposed housing allocations, but express concern about proposed housing at Bicester, Didcot and Grove.

  11. The draft Structure Plan proposed two new strategic locations for housing – land south of Grenoble Road in the Green Belt and Grove. The former attracted about 1900 objections, including from South Oxfordshire District Council, the Vale of White Horse District Council, Oxford Preservation Trust, CPRE and others. The grounds for objection are both matters of principle and site specific, including that development would set a precedent for further development in the Green Belt and that no exceptional circumstances have been identified in accordance with Government advice in PPG2. Many comment that the development would be contrary to the purposes of the Green Belt by causing urban sprawl, coalescence of settlements, and damaging the landscape setting of Oxford. Traffic problems and the ability of local services and facilities to cope with additional demand are also seen as problems.

  12. Oxford City Council support the proposed urban extension to Oxford, as a means of increasing the supply of affordable and key worker housing and providing an extension to Oxford Science Park. However, they estimate that a development of 4000-5000 homes plus an extension to the Oxford Science Park could be accommodated and suggest provision for 2500 dwellings should be allowed for within the plan period. The submission on behalf of the landowners points to a development of about 3000 dwellings up to 2016, also including an extension to the Oxford Science Park.

  13. The proposed development at Grove is supported by the Vale of White Horse provided the necessary infrastructure and services can be secured and provided, including improved links to major employment sites and Oxford. In particular the District Council urges the County Council to make the necessary resources available to achieve improvements to transport infrastructure and secondary school provision. However, concerns have been raised by some, in particular about flooding and transport infrastructure. It is also argued, in particular by developers and landowners with interests elsewhere, that Grove is not a sustainable location due to the lack of local jobs and services and poor transport links.

  14. South Oxfordshire District Council support the provision of 4500 dwellings at Didcot but consider there should be no further growth to allow the town time to absorb this and provide community facilities and services; and because there appears to be little prospect of major highway improvements to the A34 within the period up to 2016. Both South Oxfordshire and the Vale of White Horse District Councils would like the draft Plan to clarify the amount of housing to be built in each district at Didcot to reflect the alteration to the Oxfordshire Structure Plan 2011 adopted in 2000.

  15. So far as the remainder of South Oxfordshire is concerned, the District Council do not wish to allocate substantial growth to Berinsfield (the draft Plan allowed for this possibility) and wish to see a reduction for South Oxfordshire of 400 dwellings in addition to the deletion of 1000 houses south of Grenoble Road.

  16. West Oxfordshire District Council consider that the housing figure for Witney could be increased by about 300 dwellings to reflect revised estimates of urban capacity, with a corresponding decrease for the remainder of the district.

  17. On Upper Heyford, policy H2 in the draft Plan was supported by 117 respondents, including Cherwell District Council and several parish councils and local organisations. The consortium promoting the redevelopment of the airfield are seeking some flexibility to allow for about 1000 new houses on the site rather than a ceiling of 1000 (including 300 existing houses) as in the adopted policy and as proposed in the draft Plan.

  18. Some respondents suggest that if there is a case for releasing land in the Green Belt a comprehensive review of the Green Belt should be carried out. A range of alternative development locations have been suggested by developers, in particular to replace the proposed development in the Green Belt south of Grenoble Road and at Grove. These are summarised in Annex B (download as .rtf file) . New settlements have been suggested at Shipton-on-Cherwell Quarry and Sunningwell in the Green Belt, and at an unspecified location beyond the Green Belt to the east of Oxford. Some suggest smaller sites and the use of safeguarded land in the Green Belt. Other proposals are for urban extensions to the four country towns and smaller towns; in particular Faringdon, Thame and Wallingford.

  19. Concerns were expressed about the section in the draft Plan setting out possible options for development after 2016. For example, Oxford City Council object to this on the grounds that it should not pre-judge the sub regional study being undertaken by the County and district councils and other partners as part of the review of the Regional Spatial Strategy (RSS), nor pre-empt the direction of the RSS itself. Others, notably some of the development industry, echoed these comments. Objections were made by South Oxfordshire and Cherwell District Councils to identifying Didcot and Bicester for development post 2016 for a number of reasons including concerns about traffic and the A34, and other infrastructure and environmental considerations. The Vale of White Horse District Council whilst broadly agreeing with further growth for Didcot think that this should be dependent on satisfactory development in the A34 corridor. West Oxfordshire District Council asked that references to further growth at Witney and Carterton be deleted in the absence of planned infrastructure improvements to address current deficiencies.

  20. The reference to the possibility of a new community attracted few comments, including that it could divert investment and that there were more sustainable locations, and alternatively that it should be considered within the plan period.

    21. Comments of Head of Sustainable Development

  21. I consider that the key issue is whether the housing distribution and strategy proposed in the draft Plan should be amended in light of the representations and objections made and any new information which has emerged since the draft Plan was prepared.

  22. The Highways Agency, did not raise objections at the consultation stages leading to the adoption of the current Structure Plan and I do not suggest that any changes be made to the allocations established for the period up to 2011. To do so would be likely to cause unacceptable delay in delivering new housing which is currently being planned. The importance of transport networks in the A34 corridor is recognised in the plan and the Highways Agency do not appear to challenge this. We have emphasised to consultants working on the A34 Scoping Study the need to study these problems. The remaining housing proposed in the period 2011 to 2016 is quite small at Bicester and Didcot so these do not present a problem. Indeed it could be argued that proposals to increase the modal share travelling to Oxford by public transport, in particular the improvement of the premium bus network, would mean that an increase in housing allocation at Bicester could be taken without a net adverse effect on A34 traffic.

  23. Particular concerns have been expressed about the development proposed south of Grenoble Road, including the local constraints to development of the sewage treatment works, overhead power lines and switching station. There is little likelihood that the sewage treatment works could be moved with development at the current scale. The policy of the National Grid is that overhead power lines are not moved as a consequence of development proposals, and they have published guidance about how to accommodate existing power lines within development. I consider that the proposal for 1000 dwellings in the draft Plan is an arbitrary amount and that a larger development than 1000 dwellings would be necessary to address these issues and to provide for a well planned community. However, this would result in a greater incursion into the Green Belt, and any development must be justified by exceptional circumstances that outweigh harm to the Green Belt, as set out in PPG2. In agreeing the draft Plan for consultation in June 2003 the County Council resolved that apart from the provision for 1000 houses south of Grenoble Road the County Council did not see a need to release land in the Green Belt. An argument in favour of development adjoining Oxford is that it would help to address Oxford’s housing needs, including the provision for affordable housing. This issue was considered at the EIP of the adopted Structure Plan in 1997. The Panel did not recommend a root and branch review of the Green Belt, but considered that there might be scope for some limited releases aimed specifically at Oxford’s local housing needs. It is open to the District Councils to consider whether limited exceptional releases for affordable housing are appropriate.

  24. A range of alternatives have been suggested in response to the Plan for providing locations for the houses that are proposed south of Oxford and at Grove. These are listed in Annex B (download as .rtf file) .

  25. I do not consider that the development of a freestanding new settlement at another location in the Green Belt or beyond would provide a more sustainable option than an urban extension to an existing town. Shipton-on-Cherwell Quarry may appear to be a suitable option as it is not a green field site. However, although it may in time be possible to provide good public transport links to Oxford, it is some distance (12.5 kilometres) from central Oxford, remote from existing services and facilities, and is considered likely to provide only for a small dormitory settlement, contrary to Government advice on new settlements in PPG3. The Sunningwell proposal would in addition be a major green field development in the Green Belt contrary to Government policy and is unlikely to be acceptable in terms of its impact on the A34. The development near Sunningwell is being promoted as an eco-village. However, I do not consider this to be an overriding consideration as the principles of energy and resource efficient design should be applied in all development as required by policy G6 in the adopted and draft Structure Plans. Neither location is considered to meet the sequential approach to identifying locations for housing development in PPG3.

  26. Proposals for urban extensions to the country towns and smaller towns were considered by the Structure Plan Working Group when the draft Plan was drawn up. Major urban extensions to the country towns in addition to development already planned for up to 2011 were not considered appropriate (with the exception of Bicester) due to issues of transport and other infrastructure and environmental constraints. The draft Plan recommended to the County Council in April did not propose development in the Green Belt because it was considered that there was an alternative for development at Bicester which was consistent with the overall strategy of focusing on larger urban areas, without the need for development in the Green Belt. This option remains open to the County Council.

  27. Apart from the major development at Grove (see below) major extension of the smaller settlements was considered inappropriate, as this would result in greater dispersal of development and would be more likely to increase traffic generation. The draft Plan does already allow for limited expansion of the smaller settlements with the scale to be determined through the review of the local plans.

  28. Particular concerns raised about Grove are about the risk of flooding, the availability of jobs locally and the view that it is not well related to the main employment areas, including Oxford; and concerns about transport infrastructure and access by public transport. Concerns about both the flooding issue and transport are reflected in the draft Plan. The Environment Agency has not objected to the proposals at Grove. They have indicated that the former airfield site is not within a high risk flood category. There are drainage problems that will need careful consideration to design a surface water strategy to ensure that run-off as a consequence of development is controlled to the same rates as currently. The Agency assumes this can be achieved. In line with advice in PPG25 the Agency recommends that a flood risk assessment is carried out to provide more information and demonstrate how surface water will be dealt without increasing flood risk elsewhere. This would be carried out at least when a planning application is made.

  29. The need to travel from the development at Grove would be reduced by the proximity of existing facilities in Wantage and Grove. The development also has the potential to bring an improvement in local services to the benefit of existing residents. But travel is likely to be largely car dependent (except for local services) and this will have an impact on roads which are not of major route standard. However, road network improvements at Wantage and Grove can be tied to the development. The increased housing will also support the commercial viability of services on the premium bus route to Abingdon and Oxford.

  30. Grove is one of the locations to which the Highways Agency has objected because of traffic problems on A34 and the lack of remedial proposals. However, there are few destinations for traffic generated in Grove that are served by A34, so it is likely that there would be little traffic impact on the route. Furthermore, housing at Grove will help to balance the expected growth of employment at Milton Park and Harwell, thereby reducing the growth of traffic approaching on A34.

  31. It has been suggested that a larger urban extension to Oxford or a new settlement in the Green Belt would be a more sustainable location than development at Grove. A significant amount of the new housing planned up to 2016 is within Oxford. However, Oxford is not the only part of the county where there are housing requirements. The development proposed at Grove is intended to contribute to meeting housing requirements in the south of the county arising in part from the expected growth in employment in the Didcot, Harwell and Milton Park area, and to help deliver improvements to services and facilities in Wantage and Grove.

  32. In conclusion, I consider that in principle Grove remains appropriate as a strategic housing location. The issues of concern at Grove can be discussed further at the EIP, and the County Council will then have the opportunity to reconsider in the light of the EIP Panel’s report.

  33. The use of land safeguarded for long term development needs in the Green Belt was considered in preparing the Plan, but was not considered appropriate. Some areas of safeguarded land are not considered suitable for housing development or have serious access problems, while others are small in scale and would not provide strategic development locations. In any case it is open to the district councils to release these small sites through local plan reviews within their overall housing figures.

  34. PPG2 states that Green Belt boundaries should only be altered in exceptional circumstances and that if an alteration is proposed, "The Secretary of State will wish to be satisfied that the Authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt." Before any of the above alternatives are considered, the County Council should first take into account whether any additional housing potential within towns and on sites already planned for has been identified since the draft Plan was prepared. An initial estimate has been carried out which indicates that in the region of 500 – 700 additional dwellings could be accommodated. It includes the additional potential at Witney highlighted by West Oxfordshire District Council, and reflects increased densities which are being proposed on some planned sites. Further work to review these estimates will be carried out before the EIP, but as uncertainties about some locations become clearer this potential could prove to be an underestimate. How this can be reflected in changes to the housing distribution is set out in Annex C (download as .rtf file) .

  35. In conclusion, on this basis it is not considered that there is sufficient justification to release land in the Green Belt for housing within the plan period, either at the scale currently proposed or larger. Therefore it is considered that a change should be proposed to the draft Plan to delete the proposed urban extension to Oxford south of Grenoble Road, reduce the housing figure for South Oxfordshire by 1000 dwellings and amend the housing distribution to take account of the updated position on housing potential. The proposed revision to H1 is set out in Annex D (download as .rtf file) .

  36. It is not proposed to further reduce South Oxfordshire’s housing figure by 400 dwellings because the District Council do not wish to pursue development at Berinsfield. The figure in the draft Plan allowed for the possibility of development at Berinsfield but did not rely on it. It is also not proposed to reduce the figure for the remainder part of West Oxfordshire to correspond to the increase in potential identified at Witney. A reduction of 300 dwellings would mean the amount to be provided would be about the same as the estimated potential number of dwellings that could be built, allowing no flexibility for sites to be identified to meet local needs for housing. The increase proposed for the Vale of White Horse reflects an increase in capacity identified in the district and would allow the District Council some flexibility to allocate sites at settlements such as Faringdon to meet local needs.

  37. The housing distribution allows for the split of houses to be built at Didcot between South Oxfordshire and the Vale of White Horse districts. The direction of growth at Didcot and the split of housing numbers are set out in the adopted Structure Plan alteration and are already County Council policy. I agree with South Oxfordshire and the Vale District Councils that for the sake of clarity this should be reflected in the draft Plan. This can be done in the supporting text when this is amended.

  38. On the section of the Plan which looks to post 2016 there was a measure of support at the issues stage for taking a longer-term view of the county. However, while it is important that the Structure Plan provides the policy framework for the preparation of local plans or the new local development frameworks up to 2016, the issue of the longer term is now being addressed in the preparation of the regional spatial strategy (the South East Plan), which will look to 2026. The sub regional study for central Oxfordshire will contribute to this work in which the County Council has a lead role. This work should have moved forward considerably before the review of the Structure Plan is adopted, and the County Council will have the opportunity to put forward its views, taking into account representations on the draft Plan, on how it sees Oxfordshire developing in contributing to the preparation of the South East Plan. Therefore no changes are proposed at this stage.

    39. General Policies

  39. Comments on the general strategy in policy G1 include objections to restraining the overall level of development; the need to clarify which towns are the larger urban areas referred to in the policy; and that more emphasis should be placed on the smaller towns and villages and previously developed land in rural areas. Some comments suggest that Policy G3 is negatively worded, and some respondents consider the policy should ensure that infrastructure is provided in advance of development. On policy G5, it is suggested that the policy in the adopted Structure Plan prohibiting development at motorway and major road junctions should be reinstated. In relation to policy G4, GOSE have suggested that if any Green Belt is allocated for development then an equivalent amount of land should be added elsewhere as compensation. They consider that the draft Plan should indicate in general terms the location of compensatory areas if the Grenoble Road proposals are implemented.

    40. Comments of the Head of Sustainable Development

  40. The overall policy of restraint of development in Oxfordshire has been a long term strategy that has been successful in protecting the environment and character of the county by controlling development pressure while allowing the economy to prosper. I consider that this remains the correct approach, particularly given concerns about transport and other infrastructure. Although desirable, I consider it would be difficult to implement a policy requiring necessary infrastructure to be provided in advance of development, as under current legislation and guidance the funding for infrastructure cannot be provided until development is at least underway. Policy G5 in the draft Plan protects open countryside from development, and the supporting text makes it clear that this includes land in the vicinity of major road junctions.

  41. If the County Council agree with the recommendation to delete the proposed development in the Green Belt south of Grenoble Road the issue of identifying compensatory Green Belt need not be considered. In any case, I am not convinced of the value of replacing land on the inner edge of the Green Belt with land beyond the outer boundary. Although this would maintain the overall amount of land in the Green Belt, land beyond the existing outer Green Belt boundary is likely to contribute little to the purposes of designation such as preventing urban sprawl.

    42. Economy

  42. There are a number of objections to the policies for developing the economy, particularly in relation to policy E1 for Oxford. Oxford City Council consider this to be a blanket restraint on Oxford, which without appropriate criteria is harmful to key employment sectors in the City – in particular the university and health sectors. Others also comment that the policy in Oxford will be damaging to the economy of the County as whole in the long term, and is not appropriate in light of the proposed housing allocation adjoining the City.

  43. Oxford University have suggested a bespoke policy for the University and point to the need for a policy to support appropriate development in central Oxfordshire together with a framework for selective development outside the city accepting exceptional circumstances for university development in the Green Belt. An extension to the Oxford Science Park is suggested as part of the proposed urban extension south of Grenoble Road.

  44. Others comment on the wider issue of supporting research and development and the knowledge based economy. GOSE and SEERA suggest there should be a specific policy relating to business clusters. It is also suggested that the Plan should refer to major developed employment sites e.g. Harwell campus, for employment sectors that support existing and emerging growth sectors and clusters.

    45. Comments of Head of Sustainable Development

  45. At this stage I would not propose changes to the detailed wording of policies. The overall thrust of policies for Oxford and the County as a whole should be an issue for debate at the EIP at which the district councils, University and others should have the opportunity to express their views. I do not agree that policy E1 applies a blanket restraint to economic development in Oxford, as it allows for employment generating development on sites already used or allocated for that purpose. This would not prevent employment uses being included in redevelopment schemes for parts of the City such as the West End, particularly in the context of other policies in the draft Plan such as TC1. However, I think that changes to the text should be made to emphasise that the overall approach to the economy in Oxford is to achieve a better balance between jobs and housing, rather than to seek restraint of economic activity. I would also wish to bring forward changes to the text to make clear the County Council’s approach to the West End.

  46. I am not convinced that the draft plan should include a bespoke policy on Oxford University. Although it is undeniably important to the economy of the County, other organisations and businesses are also important and I do not consider there is sufficient reason to highlight one in particular. Government guidance does not suggest and I do not consider that it would be appropriate for the Structure Plan to allow for exceptional circumstances for university development in the Green Belt. As there is a presumption against inappropriate development in the Green Belt, any exceptions would be treated as departures from the plan, and exceptional circumstances must be demonstrated that outweigh harm caused to the Green Belt. This can only be done on a site specific basis. The draft Plan recommended to County Council last year provided some encouragement in policy E1 for the research and development sector in Oxford. Policy E2 in the draft Plan refers to provision for business clusters. Further consideration will be given to the issue of how to allow for appropriate growth of knowledge based industries and cluster development in consultation with GOSE, SEERA and other partners prior to the EIP.

    47. Transport

  47. Many objections seek to make the policies stronger by making the wording more definite and improving the consistency between policies. A major issue is the mismatch between the transport system, in particular the lack of road capacity, and development proposals. Another issue is the lack of information on the transport networks and absence of specific infrastructure measures for public transport, in policy T3, and for the highway network, policy T6. Most comments referring to the A34 corridor considered that study and/or upgrading here is important for further development in Oxfordshire. Individual comments sought a wide range of specific transport investment, particularly in road improvements and rail stations.

  48. There was general support for the principle of the Premium Bus Route Network, with some complaint about excessive centring on Oxford and neglect of other routes, particularly Wantage/ Milton Park/ Didcot/ Wallingford. The range of views on car parking are quite wide with some comments urging more restrictive policies as a means of restraining traffic, but a larger number urging relaxation in various special circumstances, such as at hospitals or in the less constricted centres. There are comments that there should be clearer guidance on how park and ride sites should be located and several responses considered that no further park and ride capacity should be provided on the edge of Oxford.

    49. Comments of Head of Sustainable Development

  49. It is clear that there is no immediate solution to the main issue concerning the mismatch between development and the capacity of the transport system. The County Council’s current approach combines measures to restrain traffic growth, to provide improvements in alternative choices for travel, to locate development close to where it is needed so as to avoid forcing unnecessary travel and to increase traffic capacity to serve development. The precise outcome can be influenced by changing the weight attached to each type of measure.

  50. Currently there are major uncertainties concerning what improvements in the important A34 corridor will be confirmed (in the event of this being studied). Also, Expressway Oxford is dependent on Government financial support, for which the business case is now being prepared. Against these uncertainties the Transport Networks Review (TNR) has to make recommendations for the next 15 year period beginning with the detailed 5-year programme for the next Local Transport Plan. The Structure Plan will be better able to list transport proposals that the County Council is able to support in policy T6 following consideration of the TNR report.

  51. There is a lot of detail in the comments that have been received. I expect further analysis of these to lead to suggestions for some minor changes that will improve the effectiveness of the policies. I do not at present recommend any significant change in the balance of the policies, as that would be better considered following receipt of the recommendations of the EIP Panel.

    52. Other Housing Issues

  52. The target that 55% of new housing development should be on previously developed land within urban areas is considered to be not challenging enough by some respondents including GOSE, SEERA, CPRE, and Oxford City Council, and too ambitious by others, for example some developers. Concerns have been raised that the housing densities proposed in policy H3 may not be appropriate in smaller historic towns and villages in rural areas.

  53. The priority given to affordable housing in the draft Plan is generally supported by SEERA and the District Councils, but with some uncertainty about whether the target that 50% of all new housing should be affordable is achievable. GOSE support the intention of the County Council to increase the provision of affordable housing, but are concerned that insufficient local justification has been demonstrated to pursue a policy not fully in line with Government advice. They state that robust, up to date evidence will be needed to justify the policy at the EIP. Objections to the target have been made on the grounds that it is not justified by evidence, it is contrary to Government guidance, the regional indicator should not be applied to individual areas, it does not take into account economic viability, the amount of affordable housing should be determined on a site by site basis, it is unrealistic given the need to provide other infrastructure, and it could delay housing being brought forward generally and on previously developed land.

    54. Comments of Head of Sustainable Development

  54. The previously developed land target was based on work carried out to assess the potential to accommodate development within settlements in Oxfordshire. The 55% target was considered to be reasonable at the time based on this work. I consider that the target should be reviewed following the review of housing potential prior to the EIP.

  55. In terms of the density of housing development it is Government policy to increase densities to reduce the amount of land needed for development. In order to achieve higher densities in Oxfordshire it is important for the Structure Plan to provide clear and firm guidance. Policy H3 in the draft Plan has the caveat that development should be of high quality design and should take into account site character and surroundings, and I consider it is in line with PPG3. Therefore no changes are proposed at this stage.

  56. The affordable housing target in H4 is a measure of the seriousness of the problems in Oxfordshire and the level of priority given to this issue by the County Council. It is accepted that the regional indicator in RPG9 that 48% of housing in the South East needs to be affordable is not a blanket target to be applied across the region. However, there is no evidence to suggest that levels of housing need in Oxfordshire are any less. Oxfordshire is one of the most expensive areas to buy a house in the South East, with prices for semi-detached houses on average more than 7 times average wages. The levels of housing needs identified by the district councils in recent surveys are greater than the total number of houses planned to be built. A recent survey for SEEDA found a positive correlation between recruitment problems and high cost housing areas, with Oxfordshire being one of the most affected areas. Therefore, despite the criticisms and uncertainties about delivery, I consider that the County Council should maintain the policy as currently proposed as the basis for discussion at the EIP.

    57. Minerals

  57. The great majority of representations concerned Policy M2. There is support for the principle of identifying strategic resource areas for sharp sand and gravel working in Policy M2, but a large number of objections have been made to the inclusion of the Stadhampton-Berinsfield-Warborough-Benson (SBWB) area. The reasons for objection are summarised in Annex A (download as .rtf file). A small number of objections have also been made to the inclusion of Eynsham in the Eynsham-Cassington-Yarnton (ECY) area, and to the deletion of the Sutton Wick and Sutton Courtenay areas from Policy M2. Several additional or alternative areas have been put forward, also listed in Annex A (download as .rtf file). The few objections to the other minerals policies do not raise fundamental issues.

    58. Comments of Head of Sustainable Development

  58. The identification in the Structure Plan of strategic areas where the principle of sand and gravel extraction is accepted is a well established practice in Oxfordshire. It is consistent with the Structure Plan purpose of giving strategic guidance for the development of detailed policies and site proposals in Local Plans, including the Minerals and Waste Local Plan. It does not prevent other areas to serve more local markets being identified through the Minerals and Waste Local Plan if appropriate. The objections to this approach do not raise any matters that point to it being inappropriate or requiring fundamental change.

  59. The inclusion of Eynsham in the ECY area in Policy M2 has already been established in the current Structure Plan, adopted in 1998. No change is being proposed to this area. The objections do not include any reasons to justify the deletion of Eynsham. The Sutton Wick and Sutton Courtenay areas were proposed to be deleted from Policy M2 because they have insufficient potentially workable sand and gravel resources remaining to warrant them continuing to be strategic areas for working. The objections do not include any evidence to show this conclusion is wrong.

  60. Five new areas or extensions to existing areas have been proposed in West Oxfordshire by operators and landowners. The two existing West Oxfordshire areas in Policy M2 have been assessed to contain sufficient potentially workable sand and gravel resources to provide for the period to 2016. There is no need for any new strategic area(s) to be identified in West Oxfordshire at this time.

  61. The objections to the SBWB area raise a large number of issues and express many concerns. However, these issues or concerns were known about when the area was selected. Whilst a large amount of additional, detailed information about these issues and concerns has been put forward, none of this is such as to indicate that the original assessment of the area was fundamentally wrong. The presence of important constraints within the area that limits where mineral working could take place was known about. It now seems likely that larger protection buffers around the Scheduled Ancient Monuments would be needed than originally assumed, but this would not reduce the available mineral resource to such an extent as to render the area incapable of serving as a strategic area for sand and gravel working.

  62. One matter that has changed is the size of the requirement for additional sharp sand and gravel provision in southern Oxfordshire. The Deposit Draft Structure Plan estimated this to be 7 million tonnes. Since then new national and regional guidance on aggregates provision has emerged, under which the requirement for sand and gravel provision in Oxfordshire has provisionally reduced by 13%. The additional requirement in southern Oxfordshire is now estimated to be within the range 1 to 5 million tonnes, as shown in Annex E (download as .rtf file) . Objectors consider that this reduced requirement might now be met from other areas that were previously rejected as being too small. The assessment of those potential alternative areas has therefore been reviewed, as summarised in Annex F (download as .rtf file) .

  63. Four of these areas could potentially provide sufficient sand and gravel (up to 5 million tonnes), but the location of Caversham rules it out as an area to serve the wider southern Oxfordshire market, and there are significant uncertainties attached to the other three areas. These uncertainties are such that none of these areas can be said to be as good as or better than the SBWB area. Whilst there are significant constraints on the SBWB area, it lacks the uncertainty of the other options and there is nothing to indicate that it would not be able to provide the required amount of sand and gravel from specific sites identified through the Minerals and Waste Local Plan Review. Therefore, the assessment conclusion remains the same, that the SBWB area is the best option for a new strategic sand and gravel working area for southern Oxfordshire.

    64. Other Policies – Environment, Town Centres, Energy and Waste

  64. Most of the policies in these sections in the plan did not receive a great amount of comment. The policies on the environment, recreation, and energy were largely supported, and some detailed comments on the wording of specific policies were made.

  65. Policy EN1 on landscape protection is considered to be too inflexible by some in the development industry because it goes beyond advice in PPG7 in requiring development to protect, maintain and enhance landscape character. The Vale of White Horse District Council also raise concern that policy EN1 could imply that harmful development may be permitted. Policy EN3 on agricultural land is criticised as not fully reflecting Government advice in PPG7 and RPG9, in that it should refer to the principle that if agricultural land is to be developed land of the lowest quality should be used first.

  66. The main comments on the town centre policies are suggestions that other town centres which are not specifically referred to in the draft Plan should be considered for development, for example Carterton, Chipping Norton and Abingdon.

  67. It is suggested by some respondents that the energy policies are too focused on biomass when there is significant potential to develop other sources of renewable energy in Oxfordshire as well.

  68. The policies on waste are generally supported, particularly the recycling element of policy WM2. Some respondents object to policy WM1 because it makes provision for waste from London in certain circumstances, but some industry respondents wish to see a less restrictive approach to provision for waste from outside Oxfordshire. An adjoining County Council is concerned that policy WM3 will lead to an under-provision of landfill in Oxfordshire and export of waste to other counties.

    69. Comments of Head of Sustainable Development

  69. I do not consider there to be any major issues raised which merit proposed changes at this stage. The concerns about the environmental policies will be looked at in detail before the EIP. Development in town centres apart from Oxford, the country towns and Wantage is encouraged to help sustain their vitality and viability. Policy EG1 on renewable energy is intended to be a generic policy which applies to all sources of renewable energy. I consider that the concern that sources other than biomass are not sufficiently supported can be addressed when the supporting text is amended. All the detailed comments made on policies will be revisited in preparing proposed modifications after the EIP.

  70. The restrictive approach to provision for waste from outside Oxfordshire in policy WM1 is in line with existing and emerging regional policy, based on the principles of self-sufficiency and proximity. London is a special case since it has only limited landfill capacity and Oxfordshire has the capacity and infrastructure to take some of London’s waste without undue impact, provided it is transported by rail or water. Policy WM3 seeks to ensure that where landfill is required it is used to best advantage to secure restoration of mineral workings or other environmental benefit. It does not seek to create a shortage of landfill capacity in Oxfordshire, but should be read in conjunction with policies WM1 and WM2 which seek to ensure sufficient waste management facilities for the equivalent of the total quantity of waste produced in the county (plus waste from London). Whilst it is currently assessed that there is no need for additional landfill provision, this is to be kept under review.

    71. Examination in Public

  71. The EIP will be held in October. It takes the form of a round table discussion chaired by an independent panel appointed by the Secretary of State. Participants are invited who represent a range of views to discuss issues about which the County Council would like further information before finalising the Plan. The Panel’s recommendations are not binding on the County Council, but reasons must be given for not accepting their recommendations. The Panel is supported by a Panel Secretary and Programme Officer who are recruited by, but are independent from, the County Council.

  72. The issues to be discussed and participants to be invited are matters for the County Council to decide. It is recommended that preparation of the draft and final lists of issues and participants be delegated to the Head of Sustainable Development following consultation with the Executive Members for Sustainable Development and Transport, and the EIP Panel.

  73. Following consideration by County Council on 6 April the likely timetable for the EIP and remaining stages of the review are as follows:

    74. April 2004 Advertise any proposed changes to the draft Plan for six weeks

    June 2004 Advertise draft list of issues for discussion and participants at the EIP for 28 days

    July 2004 Finalise list of EIP issues and participants

    August 2004 EIP preliminary meeting

    October 2004 EIP

    Winter 2004/05 EIP Panel report

    Spring 2005 Proposed modifications on deposit

    Autumn 2005 Adoption

    Conclusion

  74. The main issues to arise from the consultation responses on the deposit draft Structure Plan relate to the housing distribution, in particular the proposed development south of Grenoble Road in the Green Belt, and the identification of a proposed new strategic minerals area in the Stadhampton-Berinsfield-Warborough-Benson area. Having considered the issues raised, including possible alternative development locations, there is not considered to be sufficient justification to release land in the Green Belt for housing up to 2016. A revised housing distribution is recommended which deletes the proposal for 1000 dwellings at land south of Grenoble Road and redistributes these based on additional housing potential identified. In relation to the proposed new minerals area, alternative locations have been reassessed, but given uncertainties over some factors, the SBWB area is considered to remain the best option for a new strategic area for sand and gravel working in southern Oxfordshire. These issues and others raised in the consultation responses will be discussed at the EIP, following which the County Council will have the opportunity for further consideration in light of the EIP Panel’s report.

    75. RECOMMENDATIONS

  75. The Executive is RECOMMENDED:

          1. subject to consideration of the comments of the Environment Scrutiny Committee, to RECOMMEND Council to agree the proposed change to policy H1 in the draft Oxfordshire Structure Plan set out in Annex D to the report for consultation before the Examination in Public;

          2. to authorise the Head of Sustainable Development, following consultation with the Executive Members for Sustainable Development and Transport, to identify any further detailed changes to policies that the County Council might accept as an aid to discussion at the Examination in Public, and changes to the supporting text; and

          3. to authorise the Head of Sustainable Development, following consultation with the Executive Members for Sustainable Development and Transport and the Examination in Public Panel, to prepare the draft and final lists of issues for discussion and participants to be invited to the Examination in Public.

 

CHRIS COUSINS
Head of Sustainable Development

Background papers: Nil

Contact Officers:

Frankie Upton, Tel 01865 815962
Ian Walker, Tel 01865 815588

March 2004

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