Policy STRAT6: Paragraphs 2.7-2.8, Policy STRAT1

Not legally compliant. There has been no consultation on the new parts of the Green Belt that have been opened up. You have not consulted in accordance with your Statement of Community Involvement. Paras 2.7-2.8 state: “It is essential that we have sought the views and thoughts…[of South Oxfordshire people] in the preparation of this draft Local Plan….[and so] “we are undertaking extensive public consultation and engagement”. That has not happened.

Not legally compliant with the Duty to Cooperate with Oxford. Oxford’s unmet need has evaporated with their updated OAN. Destroying Oxford’s Green Belt is not un-necessarily is not in the interest of Oxford. We have a responsibility to maintain the ‘lungs’ of the city.

Policy Strat6 is unsound: unjustified, not based on proportionate evidence, and in direct contravention of the NPPF and stated government policy to protect the Green Belt except in exceptional circumstances. There are no exceptional circumstances because the housing numbers are grossly inflated.

This Plan relies on an out-dated housing needs assessment, the 2014 SHMA. It should use the revised 2018 methodology in the NPPF of 2018, for 10,000 homes, rather than 28,000 homes as here.

Solution; The Local Plan made in 2011 under the Core Strategy is still extant. Now that our objectively assessed need has dramatically fallen, that plan more than cov-ers our need. We should revert to that plan. The Green Belt should keep its strong protections.

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Policy STRAT2, Paragraph 1.13, Table 5c, Paragraph 5.12

Policy STRAT2 states that 22,775 homes will be planned for. (And then plans for 28,465). These numbers are grossly inflated. It is unsound and unjustified to rely on an out-dated housing needs assessment, the 2014 SHMA. Since then, the objectively assessed need methodology has changed with the revised NPPF in 2018.

If the Growth Deal had not pushed Council to submit its Plan by 1st April, SODC would have been obliged to use the new Objectively Assessed need of 10,000 homes, rather than 23,000 (or 28,500). Even 10,000 homes is inflated, as the OAN double-counts afford-able housing. The need, from projections of population growth according to the Office for National Statistics, is for 6000 homes (2011-2034).

This is not legally compliant with the Duty to Cooperate with Oxford. Oxford has up-dated its objectively assessed need (Oct 2018) and now needs half the homes that the original SHMA indicated. There is no Oxford unmet need to be met by South Oxfordshire. We should be building no extra homes for Oxford.

It is unjustified to ignore evidence of recent experience. We are already building too many homes: 4000 from 2011-2018, whereas only 2,500 new households have formed in the District (ONS). 1500 homes therefore have been bought to leave (or are unsold).

Housing is not a normal market with normal supply-consumption mechanisms. It has a near infinite market of foreign investors and second (third, fourth…) homers. It has been shown that increasing the supply does not reduce the price of houses to potential buyers.

We are suffering from ever increasing levels of planning blight and empty homes.An appropriate strategy would be to use the existing Local Plan 2030 which planned for 11,500 homes. It is extant. Itself, it would still result in twice as many homes as our population can fill according to projections from the Office for National Statistics (6000 homes to 2034).

It is not credible or proportionate to urbanise South Oxfordshire whilst there is no mechanism to ensure that homes are used for local workers. We risk creating ghost towns of empty and under-used homes. Indeed, the SHMA showed that 73% of homes in Oxfordshire were already under-occupied and 4% were vacant.

There should be a policy to restrict home-ownership to people working or living or intending to work or live, in Oxfordshire.

The Plan is unsound (not positively prepared) and not legally compliant in that clear infor-mation was not presented to consultees, and was not available to the Council when the Plan was passed (21st December 2018). The Local Plan is riddled with internal inconsis-tencies.

Strategy 2 states that 22,775 homes are to be planned to 2034, but Table 5c states there will be 28,465. Paragraph 5.12 explains this anomaly as to provide “additional flexibility”. Table 5c is the ONLY PLACE in the whole document where 28,465 homes are mentioned. What is our target then, is it 22,775 or 28,465?

STRAT2 is inconsistent with ENV1 - you cannot have this scale of development and pro-tect ‘South Oxfordshire’s landscape, countryside and rural areas…against harmful devel-opment.’ STRAT2 is unsound. It does not recognise the scale of ecological collapse that we face and the Plan makes no moves to redress this.

SUGGESTED WORDINGThe Local Plan made in 2011 under the Core Strategy is still extant. Now that our objec-tively assessed need has dramatically fallen, that plan more than covers our need. We should revert to that plan.

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Policies STRAT2 and STRAT6, Table 5c, Paragraphs 2.7-2.8, 2.11 and 5.12

Paragraphs 2.7-2.8 state: “It is essential that we have sought the views and thoughts…[of South Oxfordshire people] in the preparation of this draft Local Plan….[and so] “we are un-dertaking extensive public consultation and engagement”. Paragraph 2.11 states that the “consultation exercises to date…have been undertaken under Regulation 18 of the legisla-tion”. This is not so. The strategy to build extensively in the Green Belt, and to plan many thousands of extra homes over and above the SHMA and over Oxford’s (now evaporated) unmet need has never been consulted upon.

This is the first time that we have seen this completely new plan with new strategic sites, in the Green Belt, 6000 extra houses (for flexibility), and a higher number for Oxford than in the last plan on which we were consulted. Table 5c is the only place that 28,500 homes is mentioned. We are presented with a Regulation 19 consultation with the restricted consid-erations that will be made. We have had no opportunity to comment on the plan under a Regulation 18 consultation.

Furthermore, the massive amount of work that went into responding to the Regulation 19 consultation in Nov 2017 has been trashed. This shows distain for your consultees - ignor-ing our previous comments that have been viewed by no-one is not effective consultation.

The Plan is incoherent and inconsistent and cannot therefore be effectively commented upon. STRAT2 says that 22,775 homes are to be planned. And yet the sum of all the homes planned is 28,465! Table 5c is the ONLY place in the document where this number is mentioned.

Having not been consulted on the Plan, we had but 3 opportunities to comment, at Scru-tiny Committee, and then at the two meetings held in Christmas week: Cabinet and Full Council. The conduct and timing of these meetings showed a desire by Council to push the plan through without consultation.

It is clear that the votes were pre-determined and that a ‘whip’ was applied. Cabinet unani-mously passed the Plan. Holding these vital votes in Christmas week when people are dis-tracted by Christmas was a cynical attempt to avoid our scrutiny. And yet, many came. Complaints have been lodged against the Council Leader for ignoring supplicants as she chatted and laughed with her Deputy.

Full Council voted for the Plan, 21 to 9. Six of the 8 Conservative councillors voting against the Plan were suspended. Why was a whip applied?

The Council meeting did not comply with SODC’s Statement of Community Involvement: “We will ensure information is provided at the earliest opportunity and give you time to re-spond.” The plan was hastily pushed through without the provision of the full documenta-tion, not even to the Council itself. There was one appendix that was not available on-line. There were copious errors in the document, read out by the planning officer at the meet-ing. Neither the Council nor we who were speaking to Council had the full information at this important vote.

This is both unsound and not legally compliant as this is an incoherent Plan that does not comply with consultation requirements.

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Policy STRAT2, Table 5c, Paragraph 5.12, Policy H1

This Plan is not “Effective: the plan should be deliverable”. The Plan is patently un-deliverable. We have been building 623 homes a year and will have to up this to an astronomical 1600 homes a year. (We have been filling 350 new homes a year and therefore creating 270 empty homes a year - according to the ONS).

With Brexit, the known skills shortage in Oxfordshire (cf OxLEP), and the many blighted sites already in South Oxfordshire, there is no reason to think we would speed up.

In West Wallingford, an allocation for Berkeley’s homes for 555 homes was made under the Core Strategy (2011). Nothing was done. Then Berkeley’s took a site in a Conservation Area in South Wallingford on the basis that South Oxfordshire was not meeting its 5-year land supply (including presumably the lack of building in West Wallingford). 85 homes have been rapidly built there over the last year.

And last year, work (at last) began in West Wallingford - they took down most of our trees bordering the bypass, they levelled the field where larks once nested, they laid a swathe of concrete through it, and then, in September, they stopped. Apparently they will not come back until March at the earliest. Are they waiting for the slowing housing market to pick up, to offload the 85 South Wallingford homes? And mean-while staking a claim to the land so that their planning permission does not expire? Their land-banking will mean they can claim more land through an unfilled 5-year land supply (3-year for the first 2 years only under the Growth Deal).

/////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////Policy INF1 Infrastructure, STRAT2 and Table 5c

The Plan is unsound at this astronomical level of development as £9 billion is re-quired for Oxfordshire to build 100,000 homes, according to the Oxfordshire Infra-structure Plan (to 2031). There is no sign whatsoever of this level of investment.

The Growth Deal offers a miserly £150m for 5 years of infrastructure to support 100,000 homes, 2% of the amount we need. The plan is not deliverable.

The plan is unjustified in not being based on proportionate evidence on the over-stretching of our infrastructure that has occurred, with the housing we have had to-date. Our community is experiencing hardship with respect to greatly worsened traf-fic conditions, pollution of air, land and water, and overstretching of medical and so-cial care, public transport, education provision, access to green spaces etc. Auster-ity has greatly exacerbated this.

The Oxfordshire Infrastructure Strategy was drafted in July 2017. It shows that infra-structure has already fallen far short of supporting the existing new housing, and there is no plan to deliver the required infrastructure. Thus, we have fallen behind, and have no plan to deal with:

• sewage: no mechanism to increase outflow without illegal levels of river-pollution• old electricity grid: eg cannot cope with all electricity from Ardley incinerator (some

thrown away) • broadband (no plan to deliver basic broadband to over 20,000 people)• green infrastructure to protect and enhance nature (including pollinators)• air pollution: in Wallingford, Henley, Thame, Watlington – no plans likely to reduce

to legal limits • green electricity generation• carbon reduction commitments: no plan to refurbish older homes, new homes not

carbon-zero• waste recycling centres

• future requirement for fresh water• health care - plans are to close down beds• social care - budget decimated by County Council• education - under-resourced• loss of farmland to urbanisation reducing food security further undermined by

Brexit• transport - cancellation of subsidised buses has isolated communities eg Long

Wittenham• clean green transport - no plans for market towns to move people from cars to

bikes and feet• flood “risk set to worsen due to…climate change and urban development” (OXIS)

OXIS: “Oxfordshire is facing significant constraints on water, power supply and grid capacity”. It is unsound to build new homes when infrastructure has fallen behind. Oxfordshire is being developed on the cheap; it is almost entirely reliant on devel-oper contributions. It is unsound to rely on new housing to provide infrastructure when new housing is increasing the need for new infrastructure.

It should be noted that growth anticipated in OXIS will be predominantly elderly re-tirees coming into Oxfordshire with especially great needs for social and health care.

Housing allocations assume a major increase in commuting into and out of the SODC area. It is not clear how this can fulfil the requirement of sustainability.

This unsupported housing growth is likely to be detrimental to the wellbeing of exist-ing and future residents of South Oxfordshire.

/////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////STRAT 2, Table 5c, Policy EP1

In the many years that there have been known to be illegal levels of toxic air in our market towns, nothing has been done about it by the responsible party, the District Council. Since development started in 2011, and austerity removed subsidised pub-lic transport, and house price inflation separated people from their places of work, congestion and air pollution has worsened.

House prices will not reduce, and are not intended to reduce, with this huge number of unneeded homes. But congestion and air pollution will worsen.

This Plan is not legally compliant with legislation to remove air pollution from our towns, and these high levels of development will exacerbate the problem.

Solution: There should be policies for the pedestrianisation of towns, and for hopper buses around the larger towns taking people out to between-town fast transit buses and trains./////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////

Policy DES9, Paragraphs 2.3 iv, 3.4 and 9.36

Paragraph 3.4 states that “New development will meet the highest standards of de-sign with necessary associated infrastructure”. And DES9 that developments should “seek to minimise carbon and energy impacts” in DES9. And Paragraph 2.3 iv that the plan is “the plan should enable the delivery of sustainable development in ac-cordance with the policies in the NPPF.”

Development is not sustainable if it is not carbon zero or carbon negative. Develop-ment to-date has been carbon emitting, degrading of wildlife sites, adding to air and water pollution.

This low level of commitment to tackling Climate Emergency, and the low profile that global heating takes in this plan, are not compliant with the Climate Change Act of 2008, nor with the emerging Oxfordshire Energy Strategy. No targets are given. Monitoring is mentioned, but monitoring against what targets?

The District Officers have ascertained that SODC is permitted to demand higher carbon-reduction standards than building regulations require but has chosen not to insist upon carbon-zero development. This flies in the face of our Carbon Emergency and the need to halve our emissions by 2030. It does not comply with the Oxfordshire Energy Strategy (in development - see https://www.oxfordshirelep.com/energystrategy) which is to “Lead na-tionally and internationally to reduce countywide emissions by 50% compared with 2008 levels by 2030 and set a pathway to achieve zero carbon growth by 2050.”

Paragraph 9.36 does not recognise that the Climate Change Committee of Government have been tasked with increasing our target for carbon reduction in line with the UK’s ratifi-cation of the 2016 Paris Agreement.

A report in 2014 from the Oxford University (Oxfordshire’s Low Carbon Economy, www.e-ci.ox.ac.uk) clearly identifies that the only way that Oxfordshire can develop and achieve carbon reductions is to build zero carbon housing and undertake a major programme of retrofit of the existing housing stock.

The consequences of inadequate preparation for climate change adaptation and mitigation are that the Plan is unsound because it poses a substantial risk of environmental and soci-etal damage. The Local Plan should therefore set clear zero carbon standards for all new buildings, conversions, extensions and refurbishments.

In addition in Chapter 12: Monitoring and review, there should be clear and quantifiable (SMART) targets to ensure that the District’s carbon emissions fall.

All homes should be built to zero or negative carbon standards.

////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////POLICY DES10: Renewable Energy

If Oxfordshire is to “Lead…to reduce countywide emissions by 50% compared with 2008” (Oxfordshire’s emerging Energy Strategy) then pro-active planning by the South Oxford-shire would be required. With additional housing, and old homes with inefficient insulation and heating, the Plan should be ensuring that renewables are required on all new homes, and retrofit of old homes with renewables should be achieved. Development and plant for renewable energy should be planned by the District.

This plan is inadequate to address the Climate Emergency facing us, and cannot achieve legal compliance with the Climate Change Act of 2008 without more enthusiastic action.

Solution: All new homes and estates will be required to maximise renewable energy cap-ture and use.

////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////Policy DES8, Obj 1.2, Chapter 12

Objective 1.2 is to ‘support rural communities and their way of life’. This presumably in-cludes farming. The word ‘farming’ comes up once in this inconsistent, incoherent, un-sound plan. There is no clear support for farming in this Plan despite it being one of the most efficient industries in Oxfordshire (Local Industrial Strategy).

Policy DES8 states it will avoid “the development of the best and most versatile [BMV] agricultural land, unless it is the most sustainable choice” [for building upon]. This is not sound with respect to the integrity of this plan. There is no mention of protecting and en-hancing BMV land, land of Grades 1, 2 or 3a. However it "is a natural resource and should not be lost" according to various planning sources. It should be given strong protection from development, especially given the context of climate change and UK food security.

Solution: BMV farmland should not be built upon.

////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////Policies Map South December 2018, Policies Map South December 2018, All Appen-dices

The information is grossly deficient and hence does not meet the requirements of a consul-taton. The maps show only the strategic allocations, overlaying where housing existed when? In 2011?

To comment, we should be provided with maps of the existing build in South Oxfordshire. We should see where all the speculative (unplanned) building has gone in, which amounts to thousands of houses. We should see where allocations under the Neighbourhood Plans will go, even if they are only approximate at this stage. And we should see where ‘commit-ted’ building is to happen.

Take Wallingford (map South). From the map it looks beautifully clear. But the built homes, 85 in South Wallingford (in the Conservation Area) are absent. The committed Berkeley homes in the South are the same number (555) as in H2 in the West and take up the same amount of space. But all that shows on the map is farmland.

This is what I wrote in November 2017. I expect it is still true, but I haven’t the time to work through this again: “the maps omit (an estimated) 3400 homes, which the Council did not plan: speculative housing which has received planning permission or has already been built. We make this calculation from 12000 built or with planning permission minus 6600 al-located in the original Core Strategy. Is this correct? That roughly a third of the homes with permissions to-date were unplanned by the Council, and that these do not appear on any maps? We have had to calculate this ourselves as it is not explicitly stated. Thus, the extent and whereabouts of housing spreading over South Oxfordshire is very obscure.”

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Not legally compliant with regards to building on the Area of Outstanding Natural Beauty. Two new estates are planned in Nettlebed, in the AONB. This does not comply with the Na-tional Policy Planning Framework. There are no exceptional circumstances to warrant this, given that the housing targets are inflated 3-fold over our ojectively assessed need.

Solution: We should revert to the Local Plan made in 2011, based on the Core Strategy

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The Local Plan is not legally compliant with NPPF Paragraph 171: Councils should “plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries.” There is no evidence that biodiversity has been planned for at a landscape scale.

No study has been done of underlying green corridors and plant and animal types across a landscape scale and across council boundaries to ensure integrity of natu-ral life. Occasionally, the term landscape is used as an aesthetic notion rather than with deep understanding of the essential nature of not allowing plants and animals to be cut-off into islands.

The emerging Oxfordshire Plan (formerly the JSSP) has allocated no finance to as-sessing nature at a landscape scale. There is certainly no such assesment in this current SODC Local Plan.

We do not know what other non-legally compliant building will be in the AONB or on the greenbelt, or in biodiverse areas and corridors for wildlife, as the maps show only a fraction of the housing allocations (omitting homes to be planned by Neigh-bourhood Plans, omitting homes built or planned by speculative developers).

We face ecological collapse with over-development and climate change. The UK is amongst the very worst countries in the whole world for degraded biodiversity and bioabundance.

Solution: A full-scale in-depth assessment of the state of nature in Oxfordshire should be commissioned as a matter of urgency. There should be a moratorium on building until this is achieved so that building can make way for nature.

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The unjustified housing numbers, on the basis of new employment, are not credible or pro-portionate. Housing numbers are increased by expectations of unusually high growth in jobs with the industrialisation of South Oxfordshire. This includes jobs created in building the homes. Homes cannot be justified on the basis that building them creates the jobs that creates the need for the homes.

To a large extent, jobs growth, and particularly the high-tech growth identified as being the main source of new jobs by the Local Enterprise Partnership, relies on European workers. Examples are in the European collaborations at Harwell and Culham. SHMA has not been adapted in any way whatsoever to take Brexit into account. We learned (November 2017)

for example, that there has been a 90% drop in the number of applicants from Europe for nursing jobs in Oxfordshire.

Solution: We should revert to the Local Plan made in 2011, based on the Core Strategy