This document provides comments on Oxford's Local Plan 2036 regarding its vision, housing, transport, green infrastructure, and flooding. It argues that the plan's vision and policies do not go far enough to achieve sustainability goals. Specifically, it recommends that the plan set targets for Oxford to become carbon neutral by 2050, water neutral, and produce no waste or traffic growth. It also argues that the plan should do more to support co-housing, custom building, and downsizing to meet housing needs. Regarding transport, it opposes plans for an Oxford to Cambridge expressway and supports East-West rail instead. Finally, it calls for a more coordinated approach across districts to green infrastructure and soil protection.

1. Oxford Plan – Dan Scharf comments Page 1 of 9
OxfordLocal Plan 2036: PreferredOptions (the ‘Plan’)
Daniel Scharf MA MRTPI - 2017 07
These submissions are the result of conversations and collaboration with a number of people
who feel that the City Council seems to be limited in both its vision and the presentation of the
Plan as an instrument designed to assist in the transition towards a sustainable future. The
following representations cover some matters that do not appear to be included in the scope of
the Plan but which, if omitted, will severely prejudice the chance of the city and surrounding
areas contributing to the necessary achievement of the Sustainable Development Goals.
1. Vision
1.01 The Plan refers to Oxford as a ‘world-class city’. There are a number of important
measures which indicate that, in 2017, this is very far from the case. Insofar as
cohousing, the rate of self/custom building, and uptake of ULEVs, the appalling level of
homelessness (including those resorting to living on the street) and attention to the
SDGs are fundamental to a flourishing society and economy of the 21st-century, Oxford
is underachieving. Fortunately, these are matters that could and should be addressed
through the planning system, starting with the development/local plan.
1.02 The Plan refers to the direction of travel towards a Zero Carbon economy by the end of
the century. The stated level of ambition appears to not even match Central government
policy which has the objective of achieving reduction in emissions of 80% (relating to
1992 levels) and to reach zero soon after2050. There are a number of indicators (e.g.
the estimate provided by the Tyndall Institute that 10% reduction per annum is
necessary and the enhanced requirement of a 1.5° level of global warming1) that
suggest a zero carbon economy will have to be achieved long before the end of the
century. About 50% of carbon emissions are attributable to and could be reduced if not
eliminated through the land use planning system.2 A local plan covering the period to
2036 is an opportunity to mitigate against climate change (see s19 of the Planning and
Compulsory Purchase Act 2004) which cannot be missed. This is a case where it would
only make sense if 'mitigation' meant to prevent and substantially reduce, and not just
to allow to happen but at a slower rate.
1 Regrettably, the Government’s Clean GrowthPlan (previously the Emissions Reduction Plan) might
be delayed until after the closing date forthe Localplan consultation.
2 http://dantheplan.blogspot.co.uk/2017/04/planning-to-reduce-carbon-emissions-2.html
(City Voice editor’s headline:)
What is a World-class City?
Can Oxford be one?

2. Oxford Plan – Dan Scharf comments Page 2 of 9
1.03 The Plan refers to the duty to mitigate carbon emissions under s19 of the Planning and
Compulsory Purchase Act but could also cite the Bundtland definition set out in the
NPPF and the translation into simple language used by a planning inspector that
sustainable development supported by the presumption applying to plan-making in the
NPPF is that which would ‘consume its own smoke’. It is very important that the Plan
should leave no scope for unsustainable development that leaves ‘smoke’ to be cleaned
up by future generations. A ‘sound’ plan is one that is consistent with national policy
that has been through a rigorous consultation and approval process (e.g. section 10 of
the NPPF) and not just pandering to ministerial statements that can be passing fads.3
1.04 The overarching vision for the Plan should include the following objectives:
- A zero carbon city by 2050 and aiming to be carbon negative,
- A water neutral city - not producing any waste water that is not already treated
or released at a rate faster than the volume of river and rain water entering the
local area/catchment,
- A city producing no waste to landfill and,
- A city with no road traffic growth, and with policies directed at net road traffic
reduction,
- A city with no homelessness.
1.05 A significant scale of development meeting the needs of the City will occur in the
neighbouring districts. Under the Duty to Cooperate, a Statement of Common Ground
(see the 2017 Housing White Paper) or a Joint Spatial Plan, the Council (and the Plan)
should set out the conditions and standards that should apply to these developments.
This is in the context of neighbouring authorities currently operating lower standards
than the City (i.e. not acknowledging or applying s19 of the Planning and Compulsory
Purchase Act 2004) and not seeing ‘local’ mitigation as relevant to global climate (see
AECOM Sustainability Appraisal of the VWHDC Local Plan Part 2). The City should
ensure that it is not avoiding the necessary mitigation through ‘outsourcing’ the supply
of lower standard housing. The Council should also ensure that the housing in
neighbouring districts is of a type to meet the real housing needs of the City (see para
2.07 below).
3 The Council has successfully secured affordable housing contributions from developments
under 10 dwellings despite a WMS advising against – a similar evidence based approach is
necessary on carbon emissions

3. Oxford Plan – Dan Scharf comments Page 3 of 9
2. Housing
2.01 The City Council should be taking responsibility (through the respective local plans) for
the significant number of dwellings being provided in neighbouring districts to meet the
perceived need of the City. Unless there is a substantial increase in the standard of
these developments the City Council will be seen to be responsible for unsustainable
levels of carbon emissions, traffic generation and under-occupancy.
2.02 If it has not already done so, the Council should add Unlocking England's Hidden Homes4
and the 2016 HAPPI 3 report on housing for the elderly5 to its evidence base and take
account of the main findings. The problems and opportunities of housing the older
generations have been seriously underestimated. The Plan should not be looking at
housing ‘for’ the elderly but ensuring that most if not all of the new developments
within the City are ‘suitable’ for the elderly. Given the state of the existing housing stock,
the needs of the ageing population are unlikely to be met even if every new dwelling
within the country or local plan area were made suitable for an elderly household.
2.03 The needs of both the old and the young could be met through a process of “custom
splitting."6 There do not appear to be any proposals in the Plan that would meet the
expressed or latent demand for self/custom building/finishing. It is government policy
that this form of development should be encouraged in order to make a substantial
contribution to housing supply. The City Council is likely to experience extreme
difficulty in meeting their legal duty to provide serviced plots for individuals and
associations of individuals on the statutory registers and, to be ‘sound’ the Plan should
have policies that would have a reasonable chance of discharging that obligation.
Encouraging households with ‘space to spare that they would be happy to share’ to
register this interest could enable a process of reducing unsustainable levels of under
occupancy and downsizing in place to address the crisis in social care. By making a deep
energy refit a condition of the sub-division of an existing dwelling into 2 or more units,
there could be a substantial decrease in the 80% of dwellings which are currently EPC D
or below. Incidentally, the Plan should be providing for ‘consequential improvements’
in the case of any extensions to buildings which do not currently meet a zero carbon
standard. The reasons given for not doing so (including the repealed Circular 11/95?)
are not adequate to reject this important policy.
4 http://www.if.org.uk/research-posts/unlocking-englands-hidden-homes/
5 https://www.housinglin.org.uk/Topics/type/Housing-our-Ageing-Population-Positive-Ideas-
HAPPI-3-Making-retirement-living-a-positive-choice/
6 http://dantheplan.blogspot.co.uk/2017/05/custom-splittting-magic-bullet.html

4. Oxford Plan – Dan Scharf comments Page 4 of 9
2.04 The merits of Lifetime Homes should be reconsidered in favour of a combination of
Lifetime Neighbourhoods and custom splitting. The former can incentivize under-
occupation while the latter would increase environmental and social sustainability.
2.05 If, nationally, custom splitting could help raise the level of self/custom building to 20%
of 200,000 per annum (currently 7% of about 100,000) as is the case in a other world
cities, as well as being an objective of central government, then the scale of new building
in both the City and the adjoining districts could be significantly reduced. In fact,
building in the Green Belt should only be proposed or allowed when all reasonable
alternatives such as custom splitting have been explored.
2.06 The Plan does not appear to include any of the necessary support and privileging of co-
housing or community led housing. These are forms of housing which are prevalent in
many world-class cities but which are almost entirely absent in Oxford. The Plan should
include a policy to reserve7 land from larger sites for this form of housing.8 There might
also be potential to privilege purpose-built HMOs including single and two bedroom
units, but preferably tenant occupier/managed. Support for co-housing should not be
seen as pandering to a middle class elite but providing for choice (see NPPF para50)
and an example of the sharing economy that could prove to be vital to the future of the
city. It has a number of co-benefits that should be central to the objectives and vision of
the Plan.9
2.07 During the adoption of the previous local plan/core strategy the city planners told the
inspector and the Oxford Co-Housing Group that, “they were not against co-housing”.
However, by failing to apply the adopted policies to proposals made by commercial
developers they have made it impossible for the OCG, who expect the policies to be
upheld, to successfully bid for sites. The city must decide whether to prefer and adopt
policies that will be applied transparently and consistently or to include policies that
would privilege co-housing on all suitable sites. Land could be reserved for this purpose
and then released to general purpose housing if no interest in co-housing emerges.10
2.08 The evidence in support of building further family size housing is confusing. The figures
for under-occupation within the City do not appear in the Plan or the background
papers. The scale of downsizing which could take place were the Plan to ensure a
7 Reserving parts of sites will allow latent demand to surface before the development would be
allowed to be completed in more conventional form.
8 In the last 7 years the Oxford Co-housing Group has failed to find a site despite making bids for
three development sites. They could have been successfulwith the support of planning policy.
9https://www.ted.com/talks/grace_kim_how_cohousing_can_make_us_happier_and_live_longer?utm_so
urce=newsletter_weekly_2017-07-
29&utm_campaign=newsletter_weekly&utm_medium=email&utm_content=talk_of_the_week_image
10 In factthose ‘associations of individuals’ interested in custom building should be on the Council
registers.

5. Oxford Plan – Dan Scharf comments Page 5 of 9
supply of attractive options has not been estimated.11 Reference to Rightmove (2017
07 01) shows that the availability of larger dwellings for sale significantly exceeds both
one and two-bedroom units (78 x 1bed, 260 x 2bed, 315 x 3bed, 180 x 4bed and 152 x 5
bed). In the rental sector position is reversed (435 x 1 bed, 530 x 2bed, 225 x 3 bed 156
x 4bed and 169 x 5 bed). In total, there are almost exactly 1000 smaller dwellings
available and just over 1000 dwellings with three and more bedrooms. Given the
average size of household as 2.3 persons, these figures do not represent a need or
support a policy to provide any more larger dwellings.
2.09 Another reason to discount the SHMA assessment of housing need is that it finds there
to be a greater need for larger dwellings in the private sector. If anything, the need for
larger dwellings is in the rental sector. This shows that the SHMA is actually an
assessment of housing demand which reflects the market for housing for investment
purposes (which should not be a matter to be taken account by the Plan) rather than for
providing space in which to live, that is the main purpose of the Plan.12 Confusing these
measures invalidates the Plan as an instrument for the meeting of real housing needs.
2.10 Finally the Plan should be looking beyond the well-rehearsed arguments about the
unaffordability of housing and whether or not the Green Belt should be developed, etc.,
to what policies are necessary to assist in the elimination of homelessness. This might
be a complex issue where not all the answers are to be found in the planning system and
the Plan, but it is essential that the Plan includes an analysis of how planning policies
help or hinder a reduction of this distressing phenomenon that is an increasing
embarrassment and shame on those in running the council.
11 The SHMA should not be relied on as it was fundamentally flawedin this respect – even seeing a
need to build larger dwellings to meet a perceived need for ‘upsizing’.
12 http://www.redfernreview.org/wp-content/uploads/2016/11/20161114-Redfern-Review-
modelling-paper.pdf

6. Oxford Plan – Dan Scharf comments Page 6 of 9
3. Transport
3.01 The approach being taken in the Plan to the Oxford to Cambridge corridor is extremely
vague. There is reference to if not support for an enhanced road link (being promoted
as an “expressway"), but no apparent enthusiasm for the East/West rail. It should be
obvious that support for the expressway along the same corridor as the railway will
either prevent the completion of the rail link or render it unreliable and extremely
expensive to maintain. Insofar as the Plan purports to support public transport it should
be stating very clearly that it supports the rail link and that there should be no further
investigations into the expressway.
3.02 Another reason for opposing the expressway is the effect it would have on the A34 and
other feeder roads at both ends of the “corridor". Congestion would increase on the
A420 and A40 with traffic travelling to Milton Keynes, Bedford, and Cambridge. On the
contrary, East/West rail would encourage a shift from road to rail by enhancing
connections to Cambridge, Norwich and Felixstowe to the east and Swindon (incl.
Research Council offices), Bristol, Bath, Cardiff, Swansea and Exeter to the West. The
City Council should also be seeking to support the construction of a North/West slip at
Didcot to enhance the rail network.
3.03 The Plan appears to be concerned about air quality but does not include the policies
that could expedite the transition to ULEVs. The Plan should make it clear that all new
developments must provide both a number of ULEVs Including electric bikes) and
charging points. The Plan is unnecessarily cautious about the viability of car clubs. It is
very unlikely that none of the existing clubs/organisations would be unprepared to
adopt the cars provided with a development if these were first funded by the developer.
However, in that event, the Plan should require a club to be formed and run by the
residents or occupiers of the commercial development. Parking at workplaces, local
centres and the city centre should privilege ULEVs. Parking spaces in residential areas
should be limited to ULEVs and visitors.

7. Oxford Plan – Dan Scharf comments Page 7 of 9
4. Green infrastructure, flooding and bio-regional planning
4.01 The administrative ‘accident’ of dividing land use planning between five districts
creates difficulties when addressing the need for planning the bioregion comprising
most of the County of Oxfordshire. However, the City Council has functional links to the
surrounding Districts through the housing intended to meet Oxford’s housing needs.
Either through the Duty to Cooperate (or a Statement of Common Ground) or a Joint
Spatial Plan there should be concerted attempts to coordinate the use of the countryside
in terms including:
- strategic tree planning,
- soil protection,
- wetland creation,
- water retention, run-off prevention
- food production.
4.02 All open space not given to formal recreation should be planted so as to provide carbon
sequestration, food, enhanced drainage/water retention, improved air quality and
increased well-being/mental health, following the practice developed under Forest
Gardens. Such plantings provide a step towards urban food production and can be a key
part of climate change adaptation (as well as mitigation vis Carbon sequestration).
4.03 Whilst the maintenance of grass verges is not a planning matter, these should only be
provided where their management for biodiversity (and not cut/maintained as lawns)
would not cause problems (e.g. obstruction of sight lines) and complaint. All areas
without ‘forest’ trees should be planted with native wild flowers and fruit bushes,
making these available for foraging by the public.
4.04 Soil quality has been neglected by those engaged in urban development. Oxford should
adopt a Soil Strategy, using green spaces to build and improve soil, both for food
production, water retention and carbon sequestration.

8. Oxford Plan – Dan Scharf comments Page 8 of 9
5. Sustainable wellbeing - through growing people & growing food
5.01 The concept of wellbeing/happiness has gained widespread/global traction with
publication of the World Happiness Report since 201213 and in the UK the ONS has
published measures of ‘Personal well-being’ in the UK since 201114. The New Economic
Foundation has undertaken extensive work on behalf of UK Govt. to understand the
major factors that contribute to wellbeing and synthesised these in their report 5 ways
to well-being15. The New Economics Foundation has undertaken other work to produce
a Happy Planet Index16. This in an incredibly important and powerful concept as it asks
us to think about how we can manage well-being but without sacrificing the planet.
The Plan should be looking for ways to meet housing and transport needs, etc., which
are most likely to also increase wellbeing and happiness.
5.02 The UK is a signatory17 to the Sustainable Development Goals (SDGs) which replaced
and built upon the MDGs. By 2030 Goal 11.7 requires universal access to safe, inclusive
and accessible, green and public spaces which will “grow” wellbeing and sustainability.
There are a number of other goals that green spaces address - Goal 3 Ensure healthy
lives and promote well-being for all at all ages, Goal 8 Promote sustained, inclusive and
sustainable economic growth etc., Goal 12 Ensure sustainable consumption and
production patterns. Furthermore, Goal 8 specifically and several other Goals, feature
sustainability and should be read in conjunction with the Paris COP 21 climate change
declaration18.
5.03 A recent report by the Kings Fund – Gardens and health report - May 201619 makes a
strong health, social and economic case for the use of gardening/growing to improve
health and wellbeing. The Economics - Feel-better-outside-feel-better-inside-report20
highlights that 1 in 4 adults in the UK will suffer mental illness in any one year and that
the World Health Organization has predicted that depression will be the second biggest
13 http://worldhappiness.report/
14https://www.ons.gov.uk/peoplepopulationandcommunity/wellbeing/bulletins/measuringnationalw
ellbeing/2015to2016
15 http://www.neweconomics.org/publications/entry/five-ways-to-well-being-the-evidence
16 http://happyplanetindex.org/
17http://www.publications.parliament.uk/pa/cm201617/cmselect/cmintdev/103/103.pdf
18 http://unfccc.int/paris_agreement/items/9485.php
19 http://www.kingsfund.org.uk/publications/gardens-and-health
20 https://www.mind.org.uk/media/336359/Feel-better-outside-feel-better-inside-report.pdf

9. Oxford Plan – Dan Scharf comments Page 9 of 9
cause of illness worldwide by 202021. Individuals and organisations that may be
thought as within the real food, permaculture, and transition/low carbon movement
implicitly understand the links between their associated lifestyle choices and well-
being. What is less obvious to outsiders who are not passionate adherents to this
movement(s), is that activities in green spaces have the potential to deliver all actions
for well-being and are very cost effective ways of enhancing mental health.
5.04 There is a strong case that access to and work in green spaces enables all 5 ways for
wellbeing to be achieved very effectively and at the same time can build understanding
of why and how individuals can live more sustainably and so mitigate against climate
change. The national case for this has been made by Sustain in their report Growing
Health Benefits22. This vision and related objectives and policies are absent from the
current plan. While there appears to be a tension between providing land for
housing/economic benefits and green spaces/communal food growing, the economic
costs of ignoring the latter are significant. The Plan should be seen as an opportunity to
maximize the opportunities within the City for residents and visitors to flourish.
21http://www.who.int/mental_health/advocacy/en/Call_for_Action_MoH_Intro.pdf
22https://www.sustainweb.org/publications/the_benefits_of_gardening_and_food_growing/