Cherwell District Council's Local Plan is based on flawed evidence and should be reviewed

Dear Councillor,
The outcome of the recent local elections illustrated the public’s disquiet with the level of housing growth being proposed for the Oxfordshire Districts.

The Cherwell Development Watch Alliance (CDWA) finds the scale of development proposed particularly concerning because of independent analysis carried out for CDWA by the highly respected consultancy, ORS which specialises in assessing housing needs for local councils.  ORS’s report shows that the City of Oxford’s Objectively Assessed Need (OAN) for housing has been substantially overstated. 

In consequence the surrounding Districts’ Local Plans are seeking to provide more housing than is required to meet Oxford’s need.  Most councils, including Cherwell DC, are choosing to do this by taking land out of the Oxford Green Belt.  The only justification for removing land from Green Belt has to be that there are exceptional circumstances.  It is CDWA’s contention based on the ORS Report that the removal of the Green Belt land is not justified.  The real need can be met without using Green Belt land particularly if Oxford City Council’s protection of land within its boundary for employment uses were to be discontinued.

A full copy of the ORS report is attached so that you can consider it independently. 

In sum, Oxford City Council continues to rely on a figure for Objectively Assessed Need of 1,400 dwellings per annum from the outdated 2014 Strategic Housing Market Assessment (SHMA) which ORS show was far in excess of comparable authorities.

Oxford City’s own SHMA Update of 2018, written by the same authors as in 2014, identifies an OAN for Oxford City of 776 dwellings per annum but Oxford is ignoring this evidence and using the extraordinary and unjustifiable earlier figure of nearly twice that amount.

Oxford additionally claims that 1,356 dwellings per annum are needed to meet all of its affordable housing need. However, ORS also make clear that this figure is “based on a substantial over-estimation of affordable housing needs and is also an approach which is flawed and without precedent across the country”.
The particular difficulty is that only now is the Oxford City Local Plan on which these inflated figures are based, ready for examination by a Government Inspector at EIP.  Because releasing Green Belt land for housing is irrevocable, these errors need to be addressed and at the very least the current process in the surrounding Districts should be halted while this latest evidence is properly reviewed.

If Oxford was to recognise from this new evidence that their `objective` assessment of housing need was always wrong, the apportionment to neighbouring Districts of its so-called `unmet need` would reduce dramatically. If the City also changed its policy of reserving land for new employment and modestly increased its own planned housing density, it could build all the houses it needs on its own land with no requirement for the neighbouring Districts at all and no question of taking Green Belt land.

Oxford City’s figures for its housing need are a gross overstatement.  We consider that Cherwell DC should now halt the progress of its Local Plan which is based on these figures, at least until after the publication of the Inspector’s report into Oxford’s Local Plan.

If you have any questions or require further information, please email me (Giles.Lewis@opvl.co.uk).

Giles Lewis
Chair, CDWA.
30th May 2019

Cherwell Development Watch Alliance is an organisation that represents the residents and campaign groups of Kidlington, Begbroke, Yarnton, North Oxford and Woodstock.