Introducing the Oxfordshire Plan 2050

Comment ID 1082
Document Section Introducing the Oxfordshire Plan 2050 INTRODUCTION (no name) View all on this section
Respondent Judith Onuh View all by this respondent
Response Date 27 Mar 2019

Thakeham Homes Ltd are submitting representations in relation to the Regulation 18 Oxfordshire Plan 2050 consultation. Thakeham are a house builder based in Sussex, with a proven track record of delivering high quality, sustainable schemes. Thakeham are currently in the process of expanding and building on its successes to the north of London, with a number of sites currently being promoted. We wish for the following comments to be taken into account as the Local Plan progresses.

Introductory section

We welcome the consultation, but we are surprised by two things in the introductory section. First, the omission of any reference to the Growth Arc. This is odd as Central Government’s support for a Joint Statutory Spatial Plan and the choice of the end date for the Plan in 2050 is determined by the commitment of national and local government for the ideas behind the Arc. The production of Joint Statutory Spatial Plan was always integral to this. This has recently found expression in the document entitled The Oxford-Cambridge Arc: Government Ambition and Joint Declaration Between Government and Local Partners (MHCLG, 2019).

Second, the absence of any reference to this being a Joint Statutory Spatial Plan - the terminology used in the Oxfordshire Joint Statutory Spatial Plan Scoping Document (October 2018) - is also curious and not a little troubling. The Oxford-Cambridge Arc paper (MHCLG 2019), referred to above, does refer on page 24 to the Joint Statutory Spatial Plan for Oxfordshire. We note that Topic Paper 1 does refer to the Oxfordshire Plan 2050 as being the Joint Statutory Spatial Plan (JSSP). Paragraph 12 of Topic Paper 1, however, although it confirms that the Oxfordshire Plan is part of the statutory development plan, it refers to the Plan as a Joint Plan.

We ask, therefore, for clarification, and whether it is still the intention of the six Oxfordshire authorities to advance the Plan as a statutory document, or if it is to be A Joint Plan? If this is instead going to be advanced as a Joint Plan, then this could have important implications for the planning procedures that govern the way it will be implemented. While strategic sites can be allocated through either a spatial development strategy or a joint plan, Oxfordshire’s Plan

may decide that the formal allocation of a site is a matter for the local plan. The process for allocating sites, and making an application against these, therefore, needs to be clearly articulated in the next stage of the Plan (reg. 19), with reference to the NPPF.

We note in Topic Paper 1 (February 2019) that each stage of the process in the production of the Plan will require all the councils agreeing. This is similar to the process that will govern the preparation of the Greater Manchester Spatial Framework. This, though, is different from the Greater London Plan, where the Mayor has much stronger powers and is able to over-ride objections from the London boroughs. Oxfordshire does not have these powers, in part because it is not a combined authority. Yet for the Plan to be an effective planning document, it is very important that the Oxfordshire Plan does identify strategic sites, even if it does not allocate these. We note paragraph 8 of Topic Paper 1 to this effect. This will need to be made clear in the next iteration of the Draft Oxfordshire Plan.

It is also important that the Oxfordshire Plan is generous enough with its identified sites, and is supported by a strategic Green Belt review, to ensure that the Plan is flexible enough to respond to changing circumstances, as required by paragraph 11 of the NPPF (2019).

Relationship of the Oxfordshire Plan 2050 to local plans

The Oxfordshire Plan 2050 should include a section at the front of the Plan that explains very clearly how the Plan relates to local plan preparation, including what housing targets are used once the Plan is adopted and the status of any land identified or allocated by the Oxfordshire Plan 2050 and what that means in terms of development management decisions. The Plan will also need to explain clearly how any strategic policies are to be implemented in local plans, if these are allowed to vary from the wording of the strategic policy; how the five year land supply is to be calculated (collectively of individually); and the housing delivery test is to operate (will performance be measured individually or collectively?). We comment on this further below.

The Oxfordshire Plan 2050 should be very clear about the time-line of the Plan and when any reviews are planned, and what contingency measures will be put in place in the event of under-delivery, and what this means for local plan preparation.