Below are a couple of letters which residents have sent to the Rt Hon Robert Jenrick MP over his proposals to transfer Local Plan powers from South Oxfordshire District Council.
We would urge anyone concerned by his proposals to write, and we would be happy to receive and publish copies of any such letters.
Dear Mr Jenrick,
I am writing to you in your capacity as Secretary of State for Housing, Communities and Local Government.
I live in South Oxfordshire and recently became aware that you intend to overrule our District Council’s wish to withdraw the emerging Local Plan (LP2034). I think this would be a mistake, leading to avoidable problems.
The first issue is one of democracy.
LP2034 was essentially progressed by a Council that was dominated by a Party divided amongst itself and struggling to cope with a slimmed down scrutiny procedure. Conservative Councillors had been elected on a platform including protecting the Oxford Green Belt but failed to do so, causing the Leader to resign. At the same time many local people believed that the consultation process had failed to adequately recognise their concerns with the emerging plan. LP2034 was also fraught with technical problems regarding the origin of data and how it should be used, as a result the final version contains significantly more housing development than is actually needed. Although LP2034 was submitted for inspection it was very likely that the plan would not be acceptable to local people and it was therefore unsurprising to find it the dominant issue in the 2019 Council Election. The election returned a very different Council that better represented people’s concerns on this issue. The new Council, acting entirely within its rights, chose to withdraw LP2034 and in the short term depend on the existing Local Plan that can remain in force until 2027 unless superceded. Their intention is to replace it with a plan that better reflects the needs and desires of the community they represent and the wider community to which we belong. For any Secretary of State to threaten to use their powers to prevent this process would be undemocratic. When that Secretary of State is a member of a Conservative Government, attempting to enforce the flawed plan of a failed Conservative district council by removing the newly-elected district Council’s power and giving it to the Conservative county council it really doesn’t look good for democracy.
Furthermore a previous Conservative government attempted to bring greater democracy to the planning process by introducing Neighbourhood Planning. This was an entirely laudable and successful means of enabling local communities to be more actively involved in generating policy and making decisions about their local environment. Your proposed action to prevent South Oxfordshire District Council from withdrawing LP2034 is in stark contrast, it demonstrates that central Government will exercise special powers to over-ride any local democratic decisions that it doesn’t like.
The second issue is one of climate change and environment.
The UK Parliament has formally recognised the emergency resulting from climate change and its origin in our lifestyle. There is also increasing awareness of the wider environmental degradation and damage that we are causing.
Part of SODC’s reasoning in choosing to withdraw LP2034 was that it did not adequately address the climate emergency and involved unnecessary building on the Oxford Green Belt.
The environmental cost of typical large-scale housing development is massive. It starts with the mining, quarrying, excavating and processing of raw materials to make building components; the energy used and pollution caused in the manufacturing process; the haulage involved during these operations and then transporting the finished materials to the site. It involves the felling and processing of trees to create building timber. The more houses the more infrastructure is required, more road-building and utility supply systems. Most building sites also generate a large amount of waste. Every house starts its life with a huge unpaid CO2e bill.
Added to that is the impact the house has on the local environment: loss of green space and plant-life, loss of habitat, problems of drainage and sewerage. Then there is the on-going energy required to run the house. The quality of housebuilding is woefully behind the technology, housing that is CO2e neutral in its performance has been possible for decades.
SODC’s reasons for withdrawing LP2034 are grounded in actions we, as a nation, must take in order to keep our planet and country habitable. We must not build more than we need. Any building must be done to the highest environmental standard with regard to long-term sustainability. SODC’s wish to re-write the Local Plan so that at least here in South Oxfordshire we are doing that is to be applauded.
As a conservative I would hope you recognise the deeper issue of conservation here: instead of over-ruling SODC you could be working with them to pioneer the radical change in approach to planning that is required of this Government if climate change is to be successfully addressed.
I am sorry this letter arrives late in the process, but I hope it helps you to see what a bad mistake it would be to over-ride SODC on this matter and what a significant opportunity it would be to work with them.
Dear Mr. Jenrick
Residents of South Oxfordshire are profoundly concerned by the direction to our district council to suspend Local Plan decision-making. They are equally dismayed by your recent warnings that control over the Local Plan could be removed altogether from South Oxfordshire District Council.
According to your letter of 7 January 2020 to SODC, you will decide about further intervention based on the following criteria.
- the least progress in plan-making has been made
- policies in plans had not been kept up to date
- there was higher housing pressure; and
- intervention would have the greatest impact in accelerating Local Plan production
Over the course of many years SODC has worked steadily on the Local Plan and kept its policies up to date. While the planning process is in a state of suspension, SODC can rely on the Local Plan adopted in 2012 which covers the planning period up to 2027. Furthermore, SODC has a 9.75 year housing supply in place.
As for higher housing pressure, in emerging Local Plan 2034 there is a housing delivery target of 775 pa that is well in excess not only of housing demand for the district but of its share of the unmet housing need of Oxford as agreed in the Oxfordshire Growth Deal. When using the standard methodology, however, the planners arrived at 627pa as the rate of housing delivery required to meet those same commitments. If the most recent data from the Office for National Statistics were used, the minimum annual rate of housing delivery for a sound Local Plan would probably be even less. So higher housing pressure does not exist and cannot justify further intervention at SODC.
Where the fourth criterion is concerned, I cannot see how future intervention would have the greatest impact in accelerating Local Plan production at SODC. Your direction of 9 October 2019 has brought Local Plan production to a halt. Crucially, for the past three months the council has been barred from answering the initial questions from inspectors before the examination in public. As a result, local people have also been deprived of answers to their countless queries about eLP2034.
During the consultation in 2018-2019, thousands of residents commented on the inconsistencies and lack of clarity in the spatial strategy of eLP2034. We are glad to see that the inspectors have focussed on many of the same issues that local people highlighted.
- The inspectors have queried the ‘overemphasis’ on strategic sites near Oxford and the apparent lack of consideration given to housing allocations closer to Reading or other main urban areas which might offer ‘greater sustainability and social integration… with less infrastructure cost.’
- They want a better explanation about the additional uplift in housing delivery from 627 pa to 775 pa which goes beyond what is required by the Oxfordshire Growth Deal for SODC to contribute to the unmet housing need of Oxford.
- They also demand greater clarity about the ‘exceptional circumstances’ which have led to a preference for housing allocations in the Green Belt when, at the same time it has been argued that there are available sites outside the Green Belt.
Many of us were especially worried about the over-reliance on allocations in the Green Belt to achieve the housing target of 775 pa. We can take some comfort in the fact that the inspectors, in their fourth letter of 24 September 2019 demand a better explanation of the rationale (or lack thereof) for including these Green Belt sites in e LP2034.
Such was the discontent with eLP2034 that in May 2019, the local elections became a referendum on the council’s ruling group who had pushed it through. Not surprisingly the electorate voted overwhelmingly for new leadership at SODC.
Your government has honoured the will of the people to leave the EU after a referendum which had a relatively narrow majority. Yet you appear to disregard the will of voters in South Oxfordshire who have given their new district councillors a clear mandate, underpinned by a wide majority, for overhauling the Local Plan.
Ratepayers fully support SODC because it performs well by most measures. For example, IMPOWER ranks SODC and the other councils in Oxfordshire in the top ten Local Authorities of England. SODC is second in the country for waste recycling. It cannot be classed in the same league as the seventeen councils which in 2017 the then Secretary of State Sajid Javid warned could be stripped of planning powers because of failure to produce a local plan or to cooperate with other LAs.
There is no justification for preventing SODC from exercising its general power of competence in Local Plan development. Our councillors continue to fulfil their duty to cooperate with neighbouring councils through the Oxfordshire Growth Board of which the head of SODC is currently the chair. SODC like the other five LAs wants to ensure that the Housing Infrastructure Funding already granted for Didcot Garden Town and the A40 is not cut off. Surely HIF negotiations can be conducted through channels that are separate from the question of the Local Plan for SODC.
So, I urge you to work with, rather than against South Oxfordshire District Council. Please meet its leader Sue Cooper as soon as possible. And could you please allow the planners at SODC to respond to the Inspectors’ questions about eLP 2034?
We count on your cooperation with our councillors to produce a new local plan that does a better job than e LP 2034 of serving local people, preserving the rural setting of Oxford and delivering policies to tackle Climate Change at the local level.