Sites & Housing DPD Proposed Submission Document
Response to consultation submitted on behalf of JSLA
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph B1.2
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified?
b) effective?
(c) consistent with national policy? This box was ticked (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
B1.2 states: “without growth, a sustainable future cannot be achieved so Local Authorities are
expected to plan positively towards new development and to ensure that development occurs without delay”. However, B1.2 also states: “National planning policy seeks to deliver sustainable development. This is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
The Jack Straw’s Lane Association believes there is a limit to how much further development Headington and other areas of Oxford can take without seriously jeopardising the viability of traffic and transport systems and the ability of the infrastructure to cope with population growth. Planning policies must not assume that unlimited growth is sustainable.
Furthermore, City Council’s development plans are based on unrealistic expectations of the potential for encouraging modal shift from car to public transport and of not only preventing traffic growth but reducing traffic.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
The document should acknowledge that since land is finite, roads are already badly congested, water supplies in the South East are becoming a problem and population growth will exert further pressures on resources, further development in Oxford will inevitably be restricted.
________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph A3.9 Policy HP10
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association wishes to emphasise the value of private gardens in adding
character to an area, providing wildlife habitats, absorbing surface water and cumulatively helping to regulate the climate. However, the increased density of development has already had a markedly negative effect on many parts of the city and further infilling, particularly involving loss of green space, will exacerbate this.
It is very rarely possible to effectively ‘mitigate’ loss of biodiversity and the loss of gardens increases the stress on pollinators, which are vital to our food supply and whose numbers are declining at a worrying rate, partly as a result of the use of insecticides in modern agriculture. Biodiversity is not a luxury. It is essential. Notice should be taken, for example, of the extensive recent publicity regarding loss of pollinators and the need for towns and cities to address this by helping to provide flowers as a food source, for example: BBC2 3-part series, February 2012, Bees, Butterflies and Blooms http://www.bbc.co.uk/programmes/b013pw23/episodes/guide
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Emphasise the need to conserve biodiversity, not just ‘mitigate’ its loss, and preserve the habitat
that gardens and other green space provide for insects, birds and other wildlife.
_______________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP19
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that any further student accommodation along the Marston Road would bring a further imbalance in the balance of the community mix in this area, which has already seen extensive additions to pre-existing student accommodation by Oxford Brookes University.
The density of any further development on the former Government Buildings site should not be such as to exacerbate problems with flooding. Furthermore, there are already prblems with overloading of the sewers in this area, including contamination of an SSSI meadow adjacent to Edgeway Road/Ferry Road, which do not appear to have been solved by the installation of attenuation tanks.
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove the potential for student accommodation. Add requirement to assess risk of exacerbation of flooding risk and overloading of sewage system in relation to density of development.
__________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP20
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that any further student accommodation along the
Marston Road would bring a further imbalance in the community mix in this area, which has
already seen extensive additions to pre-existing student accommodation by Oxford Brookes
University. The density of any further development on the Harcourt House site should not be such as to exacerbate problems with flooding or overloading of the sewage system.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Pleaseexplain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove option of student accommodation. Add requirement to assess risk of exacerbation of
flooding risk and overloading of sewage system in relation to density of development.
__________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP23
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that in view of the pressures on accommodation as a result of the expansion of Oxford Brookes and the hospitals in Headington, it is not justifiable to allow land on the John Radcliffe Hospital site to be used for residential or student accommodation unless the accommodation is subject to a permanent restriction of use (one that remained in force with change of ownership) by junior medical staff, nurses, other hospital keyworkers who have difficulty finding accommodation at an acceptable price, and medical students.
The document does not say how much car parking space is to be lost. Current parking provision is already inadequate to meet the essential needs of the John Radcliffe and the Women’s Hospital. Some people are physically unable to get there other than by car and find taxi fares are too high. A reduction in car-parking would lead to a rise in demand for free NHS transport.
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
The amount of car parking space intended for removal needs to be known by those commenting on these plans. Impose a restriction on the type of accommodation built on the John Radcliffe site, as indicated in Q4. Indicate if any green space is to be lost - consider NHS Forest project - see Oxford Mail article, 03 02 2012, ‘Hospitals twig on to the benefits of trees’:
http://www.oxfordmail.co.uk/news/9509889.Hospitals_twig_on_to_the_benefits_of_trees/
(TinyURL http://tinyurl.com/7qh98gp)
____________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP32
Q2. Do you consider that the document is:
(a) legally compliant?
(b) sound?
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified?
(b) effective?
(c) consistent with national policy? This box was ticked.
(The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association does not consider this to be in line with National Planning Policy.
Section B1 - Introduction to Site Allocation Policies states: "B1.2 National planning policy seeks to deliver sustainable development. This is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
The potential allocation for student accommodation cannot be justified, given the large amount of student accommodation that has been built along the Marston Road and other, improved, accommodation in John Garne Way. We understand that the County Council consider this site is unsuitable for development as Extra Care housing. However, Marston Court could, in the future, be very valuable as an intermediate care home for elderly people discharged from the John Radcliffe Hospital or Nuffield Orthopaedic Centre who needed a few more days of having someone on hand round the clock and could not return to their homes because they had nobody at home to care for them. Marston Court is ideally located in relation to the Headington hospitals to offer this intermediate care, which would free up much needed acute beds for other patients. This is particularly relevant in view of population growth. Marston Court also has the potential to become Special Needs home, for which it is ideally located, with the Milham Ford Nature Park adjacent to it. Also, intensive development would exacerbate existing flooding risk and sewage problems in this area.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove the suggestion for student accommodation. Include potential to be retained as a some kind of care home. Include recognition of flooding risk and sewage problems that would arise from more intensive development.
____________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph A2.28
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association is AGAINST the addition of the category:
“Universities and colleges: lecturers at further education colleges; lecturers, academic
research staff and laboratory technicians at Oxford Brookes University or any college or
faculty within the University of Oxford” to the list of keyworker categories.”
To give the same ‘key worker’ priority to, for example, university lecturers/researchers in
Arts subjects, as to keyworkers in the hospital, ambulance, fire, police services and
other essential services, is unjustified, particularly in view of the acute shortage of
accommodation, acknowledged elsewhere in the Sites & Housing DPD Proposed
Submission document, that is available for the existing keyworker categories
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
REMOVE this new category from the list of approved keyworker categories.
____________________________________________________________________
Supplementary comments were sent on behalf of JSLA in the form of a letter:
Planning Policy Team
Oxford City Council
Ramsay House
10 St Ebbe's Street
Oxford OX1 1PT
e-mailed to [email protected]
cc:
David Rundle [email protected];
Ruth Wilkinson [email protected];
Altaf Khan [email protected]
Roy Darke [email protected];
Mary Clarkson [email protected]
Beverley Hazell [email protected]
Liz Grosvenor [email protected]
22 July 2011
Dear Sirs
Sites and Housing DPD Preferred Options – Consultation
On behalf of the Jack Straw’s Lane Association, I would like to make the following supplementary comments in relation to this consultation. Our secretary, Marilyn Cox, has completed the questionnaire itself on behalf of the Association:
1. We are concerned that the City Council has no strategic plan for managing the future development of Headington.
Over the last 10 years a total of £750 million has been spent on development in the Headington area with very little investment in the travel, transport and community facilities required to cope with the thousands of staff, patients, visitors and students the large institutions bring to the area. The draft proposals for the future development of sites in the Headington area do not assess the likely impact of development, for example, on traffic, housing, schools and other local facilities and consequently no proposals for managing these effects are provided.
In their report to the City Council, the Planning Inspectors who examined the Council's strategic policies for Oxford state that in Headington ‘expanding University and health-related developments threaten to upset the balance of the community’*
*Source: Report on the Examination into the Oxford Core Strategy Development Plan Document, File Ref: PINS/G3110/429/5, Report to Oxford City Council by David Fenton BA(Hons) MSc DipTP MRTPI and Stephen J Pratt BA (Hons) MRTPI, 21 December 2010, ‘Assessment of Soundness, Part One, 4 Justified; Effective and Consistent with National Policy’ – General 4.7, page 13.
The Inspectors recommended that the Council produce a strategic plan specifically for Headington as a basis for managing future development. No plan has been included in the present proposals. The Inspectors’ concern has not even been acknowledged.
Consequently, we consider that there should be no further significant development proposals for the Headington Area until the City Council has prepared a proper strategic plan for Headington. This plan must set out what transport/traffic, housing, schools and other facilities are required to deal with the inevitable impacts of future development
Land area, including that needed for roads, is finite. There are limits to how much more development Headington, and indeed Oxford city as a whole, can take without serious loss of amenity and biodiversity, and a substantial degradation of the quality of life of its inhabitants.
2. We consider that too many sites have been allocated for student accommodation.
We believe that the extensive building of student housing over the last 10 years has provided sufficient purpose-built student accommodation to meet the Core Strategy policy CS 25, which stipulates that no more than 3000 students of each university should live in private accommodation. The Oxford Annual Monitoring Report 2010 indicates that Oxford University has reached the 3000 target (page 21), whilst Oxford Brookes University is expected to reach the target shortly when 370 units of student accommodation at The Slade have been completed. Other student units are already in the pipeline.
Furthermore, Oxford University has stated that it is stabilising its student intake, and Oxford Brookes University has announced a reduction of 1000 in its on-campus places from September 2012 in conjunction with opting for the maximum charge of £9,000 per student. Therefore, we would prefer to see fewer sites allocated for student accommodation in favour of more sites being allocated for housing.
3. We oppose the proposal that Marston Court residential care home, Marston Road, Oxford, (Site 124) be closed. We particularly oppose the proposal that it be replaced by student accommodation.
This residential home is the only one in the Marston area. Providing alternative accommodation elsewhere in the city would be an unsatisfactory solution. Elderly people undergo considerable stress when they move into residential accommodation (or indeed out of it to an alternative residential home) and this would be substantially exacerbated if access for relatives and friends were made more difficult.
Also see comment regarding student accommodation in Point 2 above.
Therefore, if financial constraints made the closure of Marston Court unavoidable, we would wish the only preferred option to be ‘Extra Care Housing’.
4. Site 65 (Former Government Buildings) and Site 74 (Harcourt House): these sites and Marston Court (124) are in close proximity along a stretch of the Marston Road. Given the existing amount of student accommodation in New Marston (also see Point 2 above) we believe Site 65 (Former Government Buildings) & Site 74 (Harcourt House) should be allocated to housing. Also see comment regarding student accommodation in Point 2 above.
5. We oppose the proposal that some parking spaces should be lost in the Summertown (Site 49), Headington (Site 75), St Clements (Site 164) and Union Street (Site 179) car parks to allow for development.
Even people who are keen to cycle/use public transport whenever possible sometimes need to use their car to transport a heavy shopping load. Not everyone can – or wishes to - order their shopping online for delivery. The elderly and people with young children, in particular,
would be inconvenienced by any reduction in car parking spaces. Where proposals are made for student accommodation, our previous comments in this regard apply.
Yours faithfully
David Oughton
Chairman, Jack Straw’s Lane Association
(sent by email)
NB: Following the Consultation, plans to develop the Headington car park were scrapped.
See Oxford Mail, 24 November 2011
http://www.oxfordmail.co.uk/news/9380780.Traders_celebrate_as_Headington_car_park_housing_plan_scrapped/
Response to consultation submitted on behalf of JSLA
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph B1.2
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified?
b) effective?
(c) consistent with national policy? This box was ticked (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
B1.2 states: “without growth, a sustainable future cannot be achieved so Local Authorities are
expected to plan positively towards new development and to ensure that development occurs without delay”. However, B1.2 also states: “National planning policy seeks to deliver sustainable development. This is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
The Jack Straw’s Lane Association believes there is a limit to how much further development Headington and other areas of Oxford can take without seriously jeopardising the viability of traffic and transport systems and the ability of the infrastructure to cope with population growth. Planning policies must not assume that unlimited growth is sustainable.
Furthermore, City Council’s development plans are based on unrealistic expectations of the potential for encouraging modal shift from car to public transport and of not only preventing traffic growth but reducing traffic.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
The document should acknowledge that since land is finite, roads are already badly congested, water supplies in the South East are becoming a problem and population growth will exert further pressures on resources, further development in Oxford will inevitably be restricted.
________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph A3.9 Policy HP10
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association wishes to emphasise the value of private gardens in adding
character to an area, providing wildlife habitats, absorbing surface water and cumulatively helping to regulate the climate. However, the increased density of development has already had a markedly negative effect on many parts of the city and further infilling, particularly involving loss of green space, will exacerbate this.
It is very rarely possible to effectively ‘mitigate’ loss of biodiversity and the loss of gardens increases the stress on pollinators, which are vital to our food supply and whose numbers are declining at a worrying rate, partly as a result of the use of insecticides in modern agriculture. Biodiversity is not a luxury. It is essential. Notice should be taken, for example, of the extensive recent publicity regarding loss of pollinators and the need for towns and cities to address this by helping to provide flowers as a food source, for example: BBC2 3-part series, February 2012, Bees, Butterflies and Blooms http://www.bbc.co.uk/programmes/b013pw23/episodes/guide
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Emphasise the need to conserve biodiversity, not just ‘mitigate’ its loss, and preserve the habitat
that gardens and other green space provide for insects, birds and other wildlife.
_______________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP19
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that any further student accommodation along the Marston Road would bring a further imbalance in the balance of the community mix in this area, which has already seen extensive additions to pre-existing student accommodation by Oxford Brookes University.
The density of any further development on the former Government Buildings site should not be such as to exacerbate problems with flooding. Furthermore, there are already prblems with overloading of the sewers in this area, including contamination of an SSSI meadow adjacent to Edgeway Road/Ferry Road, which do not appear to have been solved by the installation of attenuation tanks.
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove the potential for student accommodation. Add requirement to assess risk of exacerbation of flooding risk and overloading of sewage system in relation to density of development.
__________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP20
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
(b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that any further student accommodation along the
Marston Road would bring a further imbalance in the community mix in this area, which has
already seen extensive additions to pre-existing student accommodation by Oxford Brookes
University. The density of any further development on the Harcourt House site should not be such as to exacerbate problems with flooding or overloading of the sewage system.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Pleaseexplain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove option of student accommodation. Add requirement to assess risk of exacerbation of
flooding risk and overloading of sewage system in relation to density of development.
__________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP23
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association considers that in view of the pressures on accommodation as a result of the expansion of Oxford Brookes and the hospitals in Headington, it is not justifiable to allow land on the John Radcliffe Hospital site to be used for residential or student accommodation unless the accommodation is subject to a permanent restriction of use (one that remained in force with change of ownership) by junior medical staff, nurses, other hospital keyworkers who have difficulty finding accommodation at an acceptable price, and medical students.
The document does not say how much car parking space is to be lost. Current parking provision is already inadequate to meet the essential needs of the John Radcliffe and the Women’s Hospital. Some people are physically unable to get there other than by car and find taxi fares are too high. A reduction in car-parking would lead to a rise in demand for free NHS transport.
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
The amount of car parking space intended for removal needs to be known by those commenting on these plans. Impose a restriction on the type of accommodation built on the John Radcliffe site, as indicated in Q4. Indicate if any green space is to be lost - consider NHS Forest project - see Oxford Mail article, 03 02 2012, ‘Hospitals twig on to the benefits of trees’:
http://www.oxfordmail.co.uk/news/9509889.Hospitals_twig_on_to_the_benefits_of_trees/
(TinyURL http://tinyurl.com/7qh98gp)
____________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Policy SP32
Q2. Do you consider that the document is:
(a) legally compliant?
(b) sound?
If you have entered No to 2(b), please continue to Q3. Otherwise go to Q4.
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified?
(b) effective?
(c) consistent with national policy? This box was ticked.
(The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound or not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association does not consider this to be in line with National Planning Policy.
Section B1 - Introduction to Site Allocation Policies states: "B1.2 National planning policy seeks to deliver sustainable development. This is development that meets the needs of the present without compromising the ability of future generations to meet their own needs".
The potential allocation for student accommodation cannot be justified, given the large amount of student accommodation that has been built along the Marston Road and other, improved, accommodation in John Garne Way. We understand that the County Council consider this site is unsuitable for development as Extra Care housing. However, Marston Court could, in the future, be very valuable as an intermediate care home for elderly people discharged from the John Radcliffe Hospital or Nuffield Orthopaedic Centre who needed a few more days of having someone on hand round the clock and could not return to their homes because they had nobody at home to care for them. Marston Court is ideally located in relation to the Headington hospitals to offer this intermediate care, which would free up much needed acute beds for other patients. This is particularly relevant in view of population growth. Marston Court also has the potential to become Special Needs home, for which it is ideally located, with the Milham Ford Nature Park adjacent to it. Also, intensive development would exacerbate existing flooding risk and sewage problems in this area.
Q5. What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
Remove the suggestion for student accommodation. Include potential to be retained as a some kind of care home. Include recognition of flooding risk and sewage problems that would arise from more intensive development.
____________________________________________________________________________
Q1. Which part of the document do you wish to comment on? (please give the relevant paragraph or policy number)
Paragraph A2.28
Q2. Do you consider that the document is:
(a) legally compliant? Yes
(b) sound? No
Q3. Do you consider the document is unsound because it is not: (tick one box only)
(a) justified? This box was ticked
b) effective?
(c) consistent with national policy? (The 3 criteria were explained in accompanying notes.)
Q4. Please tell us below why you consider the document to be unsound not legally compliant. If you do believe the document is sound or legally compliant, you may use the box to explain why.
The Jack Straw’s Lane Association is AGAINST the addition of the category:
“Universities and colleges: lecturers at further education colleges; lecturers, academic
research staff and laboratory technicians at Oxford Brookes University or any college or
faculty within the University of Oxford” to the list of keyworker categories.”
To give the same ‘key worker’ priority to, for example, university lecturers/researchers in
Arts subjects, as to keyworkers in the hospital, ambulance, fire, police services and
other essential services, is unjustified, particularly in view of the acute shortage of
accommodation, acknowledged elsewhere in the Sites & Housing DPD Proposed
Submission document, that is available for the existing keyworker categories
Q5 . What change(s) do you consider necessary to make the document sound or legally compliant? Please explain why this change will achieve soundness or legal compliance. It would be helpful if you could suggest revised wording for the policy or text in question.
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Supplementary comments were sent on behalf of JSLA in the form of a letter:
Planning Policy Team
Oxford City Council
Ramsay House
10 St Ebbe's Street
Oxford OX1 1PT
e-mailed to [email protected]
cc:
David Rundle [email protected];
Ruth Wilkinson [email protected];
Altaf Khan [email protected]
Roy Darke [email protected];
Mary Clarkson [email protected]
Beverley Hazell [email protected]
Liz Grosvenor [email protected]
22 July 2011
Dear Sirs
Sites and Housing DPD Preferred Options – Consultation
On behalf of the Jack Straw’s Lane Association, I would like to make the following supplementary comments in relation to this consultation. Our secretary, Marilyn Cox, has completed the questionnaire itself on behalf of the Association:
1. We are concerned that the City Council has no strategic plan for managing the future development of Headington.
Over the last 10 years a total of £750 million has been spent on development in the Headington area with very little investment in the travel, transport and community facilities required to cope with the thousands of staff, patients, visitors and students the large institutions bring to the area. The draft proposals for the future development of sites in the Headington area do not assess the likely impact of development, for example, on traffic, housing, schools and other local facilities and consequently no proposals for managing these effects are provided.
In their report to the City Council, the Planning Inspectors who examined the Council's strategic policies for Oxford state that in Headington ‘expanding University and health-related developments threaten to upset the balance of the community’*
*Source: Report on the Examination into the Oxford Core Strategy Development Plan Document, File Ref: PINS/G3110/429/5, Report to Oxford City Council by David Fenton BA(Hons) MSc DipTP MRTPI and Stephen J Pratt BA (Hons) MRTPI, 21 December 2010, ‘Assessment of Soundness, Part One, 4 Justified; Effective and Consistent with National Policy’ – General 4.7, page 13.
The Inspectors recommended that the Council produce a strategic plan specifically for Headington as a basis for managing future development. No plan has been included in the present proposals. The Inspectors’ concern has not even been acknowledged.
Consequently, we consider that there should be no further significant development proposals for the Headington Area until the City Council has prepared a proper strategic plan for Headington. This plan must set out what transport/traffic, housing, schools and other facilities are required to deal with the inevitable impacts of future development
Land area, including that needed for roads, is finite. There are limits to how much more development Headington, and indeed Oxford city as a whole, can take without serious loss of amenity and biodiversity, and a substantial degradation of the quality of life of its inhabitants.
2. We consider that too many sites have been allocated for student accommodation.
We believe that the extensive building of student housing over the last 10 years has provided sufficient purpose-built student accommodation to meet the Core Strategy policy CS 25, which stipulates that no more than 3000 students of each university should live in private accommodation. The Oxford Annual Monitoring Report 2010 indicates that Oxford University has reached the 3000 target (page 21), whilst Oxford Brookes University is expected to reach the target shortly when 370 units of student accommodation at The Slade have been completed. Other student units are already in the pipeline.
Furthermore, Oxford University has stated that it is stabilising its student intake, and Oxford Brookes University has announced a reduction of 1000 in its on-campus places from September 2012 in conjunction with opting for the maximum charge of £9,000 per student. Therefore, we would prefer to see fewer sites allocated for student accommodation in favour of more sites being allocated for housing.
3. We oppose the proposal that Marston Court residential care home, Marston Road, Oxford, (Site 124) be closed. We particularly oppose the proposal that it be replaced by student accommodation.
This residential home is the only one in the Marston area. Providing alternative accommodation elsewhere in the city would be an unsatisfactory solution. Elderly people undergo considerable stress when they move into residential accommodation (or indeed out of it to an alternative residential home) and this would be substantially exacerbated if access for relatives and friends were made more difficult.
Also see comment regarding student accommodation in Point 2 above.
Therefore, if financial constraints made the closure of Marston Court unavoidable, we would wish the only preferred option to be ‘Extra Care Housing’.
4. Site 65 (Former Government Buildings) and Site 74 (Harcourt House): these sites and Marston Court (124) are in close proximity along a stretch of the Marston Road. Given the existing amount of student accommodation in New Marston (also see Point 2 above) we believe Site 65 (Former Government Buildings) & Site 74 (Harcourt House) should be allocated to housing. Also see comment regarding student accommodation in Point 2 above.
5. We oppose the proposal that some parking spaces should be lost in the Summertown (Site 49), Headington (Site 75), St Clements (Site 164) and Union Street (Site 179) car parks to allow for development.
Even people who are keen to cycle/use public transport whenever possible sometimes need to use their car to transport a heavy shopping load. Not everyone can – or wishes to - order their shopping online for delivery. The elderly and people with young children, in particular,
would be inconvenienced by any reduction in car parking spaces. Where proposals are made for student accommodation, our previous comments in this regard apply.
Yours faithfully
David Oughton
Chairman, Jack Straw’s Lane Association
(sent by email)
NB: Following the Consultation, plans to develop the Headington car park were scrapped.
See Oxford Mail, 24 November 2011
http://www.oxfordmail.co.uk/news/9380780.Traders_celebrate_as_Headington_car_park_housing_plan_scrapped/