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OXFORD CORE STRATEGY Reference No: 00117 Headington and St Clements Residents’ Associations Statement following the Pre-Hearing and for the Core Strategy Examination beginning 14th July.
Matter 1: Procedure/legal requirements and general issues Issue 1: Have all the legal requirements been met? 1. This point relates to the following questions raised by the Inspector: ‘Has the Core Strategy had regard to the sustainable community strategy?’ ‘Where is the evidence that the options have been weighed and assessed, with the most appropriate strategy being pursued?’ 1.1. The issues of the sustainability community strategy and the weighing of evidence are vital to the long-term harmony and integration of existing and potential developments into residential areas, particularly those implemented and proposed by Oxford Brookes University in Headington and East Oxford. 1.2. A sustainable community is defined by the UK Planning Advisory Service as: ‘A place where people want to live and work now and in the future because of the creation of vibrant communities with a good quality of life for all. Communities and Local Government's sustainable communities plan sets out a long-term programme for delivering sustainable communities in both urban and rural areas.’ 1.3. There is, therefore, an explicit test of soundness available in the evaluation of the Core Strategy. Do the proposals lead to vibrant communities? It is our view, based on the evidence from many residential areas, that this has not been the case and is not the case for a number of the proposals in the Core Strategy. Further, this evidence has not been taken into account in determining the policies of the Core Strategy. 1.4. The increase in the number of student occupied private houses in Headington and East Oxford, combined with the large number of student halls of residence, has led to the loss of vibrant communities. It has instead led to transient uncommitted populations, a degradation in the housing stock associated with an increase in the number of houses in multiple occupation (locally this is referred to as ‘Brookes blight’), an unsustainable (to local residents) increase in noise, social disorder, crime and drunkenness, an increase in traffic and parking, a degradation and loss of local shops offering a range of goods and services, other than fast food outlets and late night drinking venues. 1.5. There is considerable evidence of a lack of sustainability due to the excessive number of students in Headington and East Oxford; evidence that has not been weighed carefully, if at all, in determining the Core Strategy. (For example, a distortion in the demographic mix, the over-representation of houses in multiple occupation and large numbers of student halls of residence.) 1.6. Planning Policy Guidance, PPG1, provides that: ‘Development plans should promote development that creates socially inclusive communities, including suitable mixes of housing’; and ‘ensure that the impact of development on the social fabric of communities is considered and taken into account;’ The high proportion of students in residential areas of Headington and East Oxford does not lead to socially inclusive communities; rather it creates excluded ghettos, either of students or of remaining residents. This has had severe effects on the ‘social fabric’ of the communities in contravention of PPPG1. Thus, the Core Strategy fails the test of soundness contravening national policy. (Reference: Planning Policy Statement 1: Delivering Sustainable Development, Office of the Deputy Prime Minister.) 1.6.2. Houses in multiple occupation and social inclusion [...]
Matter 2: Strategy Issue 1: The development of the strategy Issue 2: Place making and how the various parts of the city are intended to change
‘Place making and how the various parts of the city are intended to change.’ ‘Is the plan sufficiently explicit as to how individual parts of the City will be changed and how the various themes come together to affect specific, individual areas?’ 2.1. There is no recognition of the strategic implications concerning the extent and nature of the changes implied by allowing, and continuing to allow, an increase in the student population located in Headington and East Oxford. 2.2. In terms of place making, parts of these areas have become student and HMO ghettos; for example, estimates of over 70% HMO in the Marston Street area, 25% of the housing stock in Divinity and Southfield Roads in HMO, 50% on the Valentia Road estate and a similar figure for Little Oxford, and 30-40% in the St Mary's Road/Magdalen Road area. 2.3. The plan is not specific about how the theme of supporting the expansion in the student population, whether in HMOs or in halls of residence, comes together, if at all, with that of ensuring vibrant residential communities. In contrast, the many and obvious problems of inappropriate location of student accommodation and its effects on the local community and local economy are not addressed. 2.4. The Core Strategy should have specifically addressed the question of the imbalances implied by the expansion in the number of students and the viability of such expansion in terms of place making and themes. 2.5. There is evidence from a number of sources, which could have been used to inform the Core Strategy to reduce the number of students in Headington and East Oxford, with implications for land and housing resources, which would then be made available, especially to young families and the elderly. This would lead to place making for long-term residents, based on a demographic mix, and encourage the theme of vibrant sustainable communities, with non-transient and committed residents, with all the benefits that would bring.
Matter 5: Housing Issue 3: A balanced mix of homes Issue 4: Does the policy CS25 relate to student accommodation? Issue 7: Student accommodation 3. This point relates to the following questions or issues raised by the Inspector: ‘A balanced mix of homes’ (issue 3 of Matter 5) ‘Does the policy CS25 relate to student accommodation?’ (bullet point 12 of issue 4, Affordable housing)
3.1. The determination of the practical issue of what is
a balanced mix of homes should also include a consideration of the role
of student accommodation. The presence of a large number of students
either in HMOs or purpose built halls can and has led to severe
imbalances in the mix of homes. There are some quite devastating
examples related to Oxford Brookes University (OBU). For example, the
area around the Gypsy Lane campus of OBU has become severely imbalanced
by the number of houses turned into student accommodation on the
Valentia Road estate, estimated to be in excess of 50%, combined with
the presence of several halls of residence, for example Warneford Hall
and Cheney Hall. Such large numbers of students lead to a predominance
of one homogenous and transient group rather than a sustainable and
balanced demographic mix. 4. Matter 5, issue 7, ‘Student accommodation’ 4.1 The point addressed here relates to policies CS26 and CS30, (p.100 and 108) the Core Strategy). In particular, it considers the implications of ‘the current student accommodation position in the City’ as far as it has been affected by Oxford Brookes University (OBU) in the neighbourhoods of Headington and East Oxford. 4.2. The Core Strategy has not reflected the required active participation of the local community in determining policies relating to OBU; in this respect it fails the test of soundness through a lack of justification. 4.3 The increase in the number of students has created an imbalance and tensions between OBU and the local community. Concern about this imbalance has been voiced by residents’ associations at meetings with OBU and through other forums, such as representations to local area committees (for example, the East Area Parliament) and numerous letters to the local paper. 4.4. The Core Strategy should adequately reflect the needs of the neighbourhoods and residential areas of which OBU has become such a substantial part. The development of OBU in a residential area is not sustainable at anywhere near its present level. The size of OBU should be constrained to a level that is harmonious with the community. Our experience suggests that this would need to be broadly at the numbers on roll and located at the Gypsy Lane campus in 1999. 4.5. For a development to be sustainable there must be a harmonious and equilibrium relationship between the components; a relationship that is compatible with evolutionary growth. Presently this is not so. The areas leading to an unsustainable development include:
4.6. Bullet point 5 of point 7 raises the following question: ‘Is there realistic potential for universities to provide further residential accommodation for students … ?’. 4.6.1. The answer to this question is an unequivocal no. The provision of student accommodation has contributed to the serious imbalance referred to above. Further provision would exacerbate the situation. 4.6.2. A policy is required that emphasizes the need to use available brownfield sites to provide housing for non-transient populations, such as young families, young people who are not students and older people who seek to move out of larger accommodation units. 4.6.3. Moreover, such policies should preserve and enhance existing green spaces, which are of such great benefit to the community, such as Warneford Meadow, Warneford Hospital playing fields and the green spaces around the Marston area. 4.6.4. It is non-transient, rather than transient, populations that support and benefit the community structure, local services and the cohesion of neighbourhoods; and those who feel committed to the area in which they live by virtue of financial contributions, such as council tax, and who see long-term benefit by respecting the needs of their neighbours. 4.7. Bullet point 6 of point 7: ‘… Should the policy go to identify where and how further student accommodation could be provided?’ In our view the answer to this question is no. Decisions concerning the location of student accommodation, that are at least potentially sustainable, should allow local communities the opportunity for a genuine part in the decision making. To identify where such student accommodation should go in advance, is to undermine the process of community involvement. 4.8. Implications for Policy CS30 Policy CS30 provides that ‘Planning permission will be granted for proposals at Oxford Brookes University that deliver more efficient and flexible academic buildings and high-quality urban design … 4.8.1. Policy CS30 should be deleted. This policy presupposes that such developments, which may be proposed, would be warranted; but this is not so, as there is substantial disharmony and disequilibrium caused by the present scale and location of Oxford Brookes University in this residential part of Headington. 4.8.2. Policy CS30 should be replaced by: 'Oxford Brookes University should be required to reduce further the number of full-time students living in private rented accommodation to 2000, from the present Local Plan target of 3000, before any replacement of existing buildings can take place. Any new building should not have the effect of increasing the total area of teaching/administration space from that prevailing on the 1st January 2009'. 4.8.2. Policy CS30 is not operational and is not capable of being monitored and thus fails the test of soundness: neither it, nor the paragraphs relating to it, defines the terms ‘efficient’ or ‘high-quality’; therefore, the question of whether a proposed development meets these criteria cannot be determined.
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