Oxford Preservation Trust (OPT) welcomes this opportunity to comment on the proposed reforms to the National Planning Policy Framework.
OPT was established in 1927 as a charity and local amenity society with the principal aim of conserving and enhancing Oxford and its setting. It takes a forward thinking and positive approach to development, looking to influence change rather than stopping it, preserving the best of the old and encouraging the best of the new. It is committed to ensuring that Oxford can continue to flourish and prosper, whilst protecting its historic character and setting. OPT engages with the planning process, taking a strategic approach to commenting on planning applications and policy.
OPT owns around 1,000 acres of land in and around Oxford, promoting increased biodiversity and making green space available for local people to benefit from and enjoy. A large proportion of the land that OPT owns is located within the Oxford Green Belt.
Whilst OPT is generally supportive of the aims of the proposed reforms, we have some concerns which are set out in below.
1 Oxford – a city with specific constraints
Oxford has developed at the confluence of two rivers in what is effectively a ‘green bowl’. Its built heritage is iconic and recognised around the world. The connection between the built environment and Oxford’s setting within the wider landscape is a fundamental element of Oxford’s heritage significance. The network of green fingers that extend from the surrounding countryside along the river and canal corridors and into the heart of the city also play a key role in Oxford’s overall character. The Oxford Local Plan, Oxford Heritage Plan and associated Technical Advice Notes and SPD’s all highlight the high heritage significance of the City, and the critical role the green setting plays in this.
The 1972 Local Government Act came into force throughout the country in 1974. Oxford became a district authority in the county of Oxfordshire, and the city’s boundary was set at this point. Due to the importance of the city’s green network and setting, around its historically significant centre, the boundary has remained largely unaltered since that time. This leads to a serious constraints with limited space for growth.
Whilst the NPPF aims to provide an over-arching framework for the Government’s planning policies, it is crucial to remember that the policies within it need to apply to a wide range of areas and settlements, each with their own limitations and opportunities. A one size fits all approach will not work.
The new framework should acknowledge and provide for the distinctive characteristics of different areas, equipping the relevant local authorities with the tools to protect them within local plans and other local levels policy documents.
2 Calculation of housing requirements
The proposed reforms include the removal of the December 2023 changes to the NPPF and the return to “mandatory” housing targets. Whilst OPT supports moves to boost more housing delivery, we are concerned that the proposed changes will place additional pressure on Local Authorities to release sensitive green field, and green belt areas of land to accommodate this growth.
As discussed above, Oxford is a highly constrained City completely surrounded by Green Belt with limited land within its administrative boundaries to accommodate ongoing large scale housing development. Any increase in housing requirements will inevitably put pressure on the surrounding Green Belt to accommodate this need. OPT believe that alternative methods for calculating housing requirements should be provided to account for different geographical restrictions – a one size fits all method is too blunt a tool and could lead to the loss of sensitive and important green landscapes.
OPT strongly supports the continued guidance encouraging effective co-operation between neighbouring local authorities. This can play a vital role in ensuring that additional housing need accommodated across a wider area, rather than concentrating all growth within one local authority area, if land designations (such as Green Belt) would make that difficult.
OPT supports the guidance (Paragraph 79) proposing methods to help ensure that housing development is implemented in a timely manner. We believe that this should be strengthened. With the re-introduction of the 5-year housing land supply targets, it may be in some developers own interest to delay the delivery of housing, ensuring a shortfall to pressurise local authorities into releasing further sites. Clear guidance needs to be given so that Local Authorities have the tools necessary to prevent this from happening, ensuring that schemes are built in a timely fashion once they receive planning permission.
3 Protection of the Green Belt
Paragraph 124c (now 122c) strengthens the brownfield first approach, which is something that OPT strongly supports. However it goes on to say that, where housing, commercial or other identified needs cannot be met, authorities will be required to review their green belt boundaries and must allocate land to meet needs in full “unless there is clear evidence that alterations would fundamentally undermine the function of the Green Blet across the area of the plan as a whole” (Paragraph 145, now 142).
OPT has serious concerns about this step-change. In Oxford, there are limited large areas of brownfield land currently available for development within the established city boundaries. The proposed change in Green Belt policy has the potential to place immense pressure on the local authority to release green belt land to accommodate development.
Green Belt land has traditionally been protected by a strong presumption against development – and there has been good reason for this. Green Belt land only covers approximately 13% of the total area of England and has been designated in a relatively small number of locations to prevent urban sprawl and protect the countryside.
The return to “mandatory” housing targets and 5 year housing land supply will result in huge pressure to release green belt sites to accommodate development. Clearer guidance should be set out within the NPPF to make it clear that these areas should continue to be a ‘last resort’ for development, with high levels of protection set out in policy.
4 ‘Grey belt’ land
A clear definition needs to be given on what will constitute ‘grey belt’ land within the Green Belt. Setting out a new sub-category of land, within an already clear and established designation – will lead to confusion and the potential for developers to exploit any ambiguity.
OPT is concerned that the introduction of the ‘grey belt’ land will lead to pressure on authorities to release any previously developed land within the green belt for re-development, including areas in agricultural use. Whilst some areas may be suitable, it must be made clear that not all ‘grey field’ sites will automatically be acceptable in principle, and that the five key purposes of Green Belt land will still need to be considered.
OPT believes that the introduction of a new sub-category within the definition of Green Belt land will be confusing. As such the term ‘grey belt’ should be removed from the document and the guidance covered within amended paragraphs 151 and 152 is considered sufficient to guide and manage future potential development in the Green Belt.
5 Strong presumption in favour of brownfield development
OPT supports the brownfield first approach; the NPPF should seek to encourage urban development in existing urban areas, ensuring development is located close to existing services and facilities.
The proposed changes seeking to boost housing delivery are to be commended with brownfield land playing a critical role. Alongside this it is important to recognise that the countryside has its own value and needs to remain separate from cities and urban areas. Countryside provides us with food security, nature and ecology benefits, health benefits and has its own role to play in the climate emergency. Sufficient weight needs to be given in policy terms to the protection of these areas to enable local authorities the power to protect them through the development control process.
6 Strategic approach to renewable energy schemes
In national policy terms, the issue of climate change should be taken as seriously as the provisions for housing and economic growth.
A strategic approach is needed to manage the pressure for renewable energy schemes, which are often proposed – in ad-hoc and unplanned ways – on green field and green belt sites. This results in the loss of large areas of countryside, loss of the Green Belt and the loss of areas of high value agricultural land. Whilst OPT acknowledges the climate change emergency and the role that planning can make in delivering renewable energy, equal weight needs to be placed on protecting important natural resources.
The emphasis on increasing housing delivery misses an opportunity to consider how existing development can contribute towards mitigating the effects of climate change. The retrofitting of existing homes and buildings should be promoted, with reference to the careful balance that needs to be undertaken when heritage is a consideration. Improving energy efficiency in historic buildings shouldn’t come at the cost of damaging the historic character of the building.
Also to be encouraged is an increased environmental requirement for new developments. This would require the incorporation of renewable technologies in all homes and buildings.
7 Opportunities to build upwards
Paragraph 122e states that planning policies should support opportunities to use airspace above existing residential and commercial premises for new homes where development would be consistent with the prevailing form of neighbouring properties. OPT is concerned that the general presumption in favour of building ‘upwards’ is too general and does not take into account factors such as heritage or protected and sensitive views. In cities such as Oxford, the height and massing of developments within, and close to, the highly significant historical city centre needs very careful management. Not all areas and sites are suitable for upwards development and this should be reflected within the text found within paragraph 122e.
We hope that the our comments will be taken into account when finalising the proposed reforms to the National Planning Policy Framework. The House of Lords Built Environment Committee is conducting an inquiry in October, into the plans to designate “grey belt” land for development. It would seem sensible to wait for the outcome of this inquiry before finalising the proposed reforms to the NPPF.