Comment
Oxfordshire Plan 2050: strategic planning or lack of ambition?
Drafts of the Regulation 18 (part 2) version of the Oxfordshire Plan 2050 have been published for consideration by committee, and are expected to be published for formal consultation towards the end of July 2021 for 10 weeks. This brings forward and clarifies a delayed and uncertain, but hugely significant, part of the Oxfordshire (and Oxford - Cambridge Arc) ‘planning puzzle’. In this article we explore the associated political issues, the ambition of the Plan and provide some thoughts as to how this should now progress.
The consultation document is available here.
Background and context
The Oxfordshire Housing and Growth Deal (‘the Deal’) was signed in 2018 and sets out expectations and planning flexibilities in the context of an ambitious plan for growth.
The Oxfordshire authorities would plan for the delivery of 100,000 homes (2011 – 2031) and produce a Joint Statutory Spatial Plan (‘JSSP’) by 2021. In return, the Government would apply a three year housing supply requirement until the adoption of the JSSP, with a bespoke Housing Delivery Test to be applied once the JSSP is adopted and grant £215 million of funding to help deliver affordable housing and infrastructure improvements.
In his Statement of 25 March 2021, the Minister of State for Housing confirmed that the period of time for the preparation of the JSSP has been extended to 2023 (but he did not extend the three year housing land supply flexibility).
The Outline Agreement for the Deal expected the draft JSSP to be published in October 2019, with submission in March 2020 and adoption in March 2021. Since then, the political context in much of the county has shifted and Local Plans have been adopted (and challenged in the courts), and planning reform has been proposed at a national level. Significantly, in this case, the Oxford-Cambridge Arc initiative has progressed and we now know the likely timescale for the Spatial Framework, with the draft Vision likely to emerge in the coming weeks.
Politics: Who is doing the planning?
The consultation document needs to be approved by each of Oxfordshire’s planning authorities before the public consultation can commence. But how does cross boundary, long term plan policy making work when those approving are focused on short term political issues, securing seats and winning more in the next round of local elections?
Oxfordshire (including the County Council) has two Conservative councils, one Labour, one Liberal Democrat and two with no overall control. This range of parties feels more likely to lead to the Oxfordshire Plan becoming a political football than to a coalition of leaders looking to implement policies to achieve a ‘better Oxfordshire’.
Local politics at play
The right thing can often be lost when quick wins are available, as seen recently with the Liberal Democrats’ realisation that becoming the English NIMBY party might bring them back to a semblance of their former selves. This is particularly notable for Oxfordshire County, which prior to the May 2021 local elections had been led by a minority Conservative administration with support from an Independent. However, a surge in votes for the Liberal Democrats and Greens saw the Conservatives lose eight seats, including that of the Oxfordshire County Council leader Ian Hudspeth.
Where the Liberal Democrats campaigned for “infrastructure before housing”, Mr Hudspeth had been associated with the Growth Deal and the Oxford-Cambridge Arc project, and the ‘No Expressway Group’ claimed his defeat as its victory.
With such a mixed array of governance arrangements across the Oxfordshire authorities, there will undoubtedly be some knock-on effects to the formulation of the Oxfordshire Plan 2050, and no doubt this has contributed to the delays in Plan formulation we have seen to date. The withdrawal of strategic planning mechanisms has not helped this exercise. These are difficult decisions, but political leadership for strategic planning exercises such as this must transcend local political cycles, provide the framework for Oxfordshire over the next 30 years, and likely beyond. This approach should necessarily be positive, visionary and brave.
Housing ambition
So how does the emerging Plan seek to deal with these challenges, most notably regarding housing growth? The growth needs for the JSSP have been identified using the Oxfordshire Growth Needs Assessment (OGNA) which focuses on three levels of growth: “Standard Method adjusted”, “Business as Usual” and “Transformational” which will be considered during this consultation.
Each of these options provides a different housing needs figure (adjusted Standard Method 3,386 pa; Business as Usual 4,113 pa; Transformational 5,093 pa) and have been compared against the Growth Deal figure of 5,000 pa.
When looking at the three housing need options provided in the consultation document, only one of the options comes to the level of housing required by the Deal. The Transformational option assumes the delivery of 5,093 homes per annum with a total of 152,790 dwellings over the plan period. This is broadly consistent with the requirements of the Deal to 2031.
Fundamentally anything below the Deal requirements to 2031 is likely to undermine the Deal itself, and the reasons why 100,000 homes were sought by 2031 – particularly as it was based on addressing affordability issues and supporting economic growth.
The draft JSSP also provides a breakdown of the ‘committed growth’ identified in the adopted Local Plans within the Oxfordshire Plan area in order to identify the ‘residual’ levels of growth associated with the options identified in the OGNA. However the calculations are based on inconsistent approaches, occasionally on requirements, and occasionally on planned supply. This inconsistency has long been reflected in Local Plan making and there has been concern as to whether the Local Plans ‘require’ the level of development to support the Deal. Clearly the JSSP is an opportunity to ensure that a Plan is in place to ensure that those needs are met.
Respondents to the draft JSSP will of course see the three growth options and the consequential residual levels of growth required. There is a real prospect, given changing politics and local objection to specific sites, that many respondents might support the options which deliver lower levels of growth and result in a lower residual requirement. If that approach were then adopted, it raises the fundamental question of whether this is a Plan which delivers aspirational growth, is ambitious, supports jobs, addresses affordability and is transformational.
Previously when considering the outputs of the 2016 Strategic Housing Market Assessment (‘SHMA’), the local authorities ran with the midpoint figures, and these have informed subsequent Local Plans. Even the midpoint figures in this current consultation may be viewed by the current political leaders as ‘too much’.
Not only is the level of growth to be supported by the JSSP key to Oxfordshire, but of course Oxfordshire itself is key to the Oxford-Cambridge Arc where aspirations are developing to deliver one million homes by 2050. Failing to support growth in Oxfordshire runs the risk of failing to support a key part of the Arc.
Concluding comments
The form and content of the JSSP has long been uncertain. Would it allocate sites, would it set requirements, would it be a forward thinking document which really supports the ambitious growth programme required to address affordability, house prices, and support the hugely important economic role of the county?
Regional and strategic planning is dead, right? Yet, all of Oxfordshire is subject to an emerging JSSP to cover the period to 2050. We understand that this document will be a statutory part of the Development Plan once adopted. It will therefore need to do, or support, all the things a Local Plan would be expected to do. But will all the authorities adopt it, and if not, then what happens? In the early stages of the Growth Board, one of the local authorities refused to sign the memorandum of understanding (MOU) on the apportionment of Oxford City’s unmet needs. Since then, the political complexities in the county have become more diverse, with competing agendas and expectations, and we have seen challenges to two recently adopted Local Plans.
The whole of the county is within the Oxford-Cambridge Arc, where the Spatial Framework is expected to be afforded the same status as the NPPF. In Oxfordshire at least, regional planning isn’t dead, but the issue is that it is a complex part of a bigger, more difficult puzzle, coming forward at a time of shifting politics and with real concerns over its ambition.
We have long speculated that the JSSP might be akin to the sub-regional strategies contained in the South East Plan, by outlining the role of places. That appears to be where this JSSP is heading, however the reality is that there are brave decisions to take in order to ensure that this JSSP does support the ‘ambitious and innovative’ and ‘transformative’ change referred to.
This might not allocate sites, but it will set the tone for the forthcoming Local Plans in the county and so it is critical that those who wish to promote schemes which might be delivered over the next 30 years or so engage with the process.
Rather than skirting around the issue, the JSSP should be focused so that from the outset it is truly ambitious, innovative and transformational. That is the context and reason for the Plan after all.
For further information please contact David Murray-Cox, Tim Burden, Andrea Kellegher or Sarah Hockin.
8 July 2021
