Dear Ms Biggs
Emerging South Oxfordshire Local Plan
Thank you for your letter dated 13 June 2018 and subsequent email of 1 August 2018.
There are four matters on which I can respond:
- Consultation on the Reading sites;
- No information available on criteria for sites;
- Concerns about the Core Strategy policy not being adhered to;
- Inviting comments from only site promoters;
- Withdrawal of Reading sites from the Local Plan site assessment process.
Consultation on the Reading sites
Irrespective of whether the three sites at Reading are proposed for inclusion in the Local Plan or whether they are justified for exclusion as a strategic allocation, following the Council decision scheduled for 20 December 2018 a consultation period will be held.
That consultation will be an opportunity to have an informed view on the Council decision on strategic allocations in a revised Local Plan Publication Version, and importantly the evidence that the Council has used to make that decision. This will mean that none of the fifteen sites being assessed will have any perceived benefit of having been subjected to a consultation.
No information available on criteria for sites
The allocations for housing within a local plan have to meet requirements set out in the National Planning Policy Framework at paragraph 35:
South Oxfordshire District Council, 135 Eastern Avenue, Milton Park, Abingdon, Oxfordshire OX14 4SB www.southoxon.gov.uk
“Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, andwhether they are sound. Plans are ‘sound’ if they are:
- a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
- b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
- c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
- d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.”
The District Council has no set process to follow when allocating strategic housing sites, but it must justify its allocations. Importantly the Council and the Planning Inspectorate must be satisfied that the allocations are the right ones and that they are not being proposed without a full and proper consideration of any reasonable alternatives. This assessment is a complex and lengthy process and it will be scrutinised at the examination of the Local Plan, particularly by promoters of reasonable alternatives that the Council dismisses from allocation. The Council would not release information about the assessment process or any interim outcomes before the evidence is collected and the assessment is complete, including the criteria it is using to justify its ultimate allocations. Doing so would undermine the Councils position before it has an opportunity to consult widely.
Concerns about the Core Strategy policy not being adhered to
The hierarchy policy you refer to deals with apportioning growth to different tiers of settlements. The site assessment process being undertaken is seeking the right strategic allocations for the Local Plan, it is not reconsidering apportionment of growth to settlements. No change to settlement policy has been proposed by instigating a site assessment process for strategic allocations.
Inviting comments from only site promoters
The District Council has been and will continue to be working very closely with Oxfordshire County Council and Reading Borough Council on an ongoing basis as this site assessment process continues. Input has been provided by a range of stakeholders informally to help the Council gather the necessary evidence and information.
Withdrawal of Reading sites from the Local Plan site assessment process.
An early dismissal of any of the fifteen sites without a robust justification will make it more difficult to argue that any sites proposed to be dismissed should not be allocated; It would also make it difficult for the Council to justify its proposed allocation of sites if we do not consider those sites against the other reasonable alternatives on a fair and equal basis.
Head of Planning