27th November 2017

SODC Emerging Local Plan 2011-33 – Final Publication Version October 2017
In this document our comments relate only to the part of the Emerging Local Plan which deals with the Oxford Brookes University Wheatley Campus (Policy STRAT10).
We wish to make it absolutely clear that the Oxford Brookes Wheatley Campus is in the parish of Holton, not Wheatley, so the first paragraph of Para 4.63 on page 48 is not required as the Green Belt status of Wheatley is irrelevant. Holton Parish Council gave permission for only part of the campus to be included in what was originally intended to be the Wheatley and Holton Neighbourhood Plan as it was felt that, with the impending move by Oxford Brookes from the site in Holton, it should be included within a Neighbourhood Plan for consideration within that plan. Holton did not have the resources to formulate such a plan for one small part of the parish and as a smaller village washed over by the Green Belt had no reason to do so.
As a general point we do not understand why South Oxfordshire District Council should choose to designate the Oxford Brookes Wheatley Campus as a Strategic site for housing when there are potentially many other uses for the site including its current use as an educational establishment.
If it transpired that housing was deemed to be the most appropriate use of the site, it should be made absolutely clear that:
• housing should be confined to the previously developed land only, and
• land within the Green Belt which has not been previously developed should not be used for housing. The Local Green Belt Study for South Oxfordshire District Final Report 14 September 2015 on page 48, with a map on page 46, refers to a “suggested inset boundary of University campus, including the main built up area and access road, hard courts and playing fields north of the A40 which do not display essential Green Belt characteristics. The boundary is set tight to the northern edge of the built form to protect the setting of Holton.” South Oxfordshire District Council cannot fail to take on board their own Green Belt Study although the Study’s suggestion that the playing fields north of the A40 do not display essential Green Belt characteristics is entirely without foundation as Appendix 1 shows.

Our specific comments on the content of the Plan are as follows:
1. Land at Wheatley Campus Para 4.61 page 48
The statement “The surrounding uses are predominantly residential” is not correct as reference to any photograph or map of the site demonstrates, for example see Appendix 1. There is residential use on only one side of the site and that is completely separated from the site by the A40 Trunk road and substantial tree planting.
2. Land at Wheatley Campus Para 4.65 page 48
It is probable that the Listed Building referred to is the Old House at Wheatley Park School. Reference should also be made to protecting the views towards the site from St Bartholomew’s Church in Holton which is Grade 1 Listed and within approximately 300 metres of the site.
3. Land at Wheatley Campus Para 4.66 page 49
We are concerned about the phrase “at least 300 new homes” (emphasis added) which is repeated in Policy STRAT10: Land at Wheatley Campus, Oxford Brookes University. This is not a term used in relation to other sites mentioned in the Local Plan document and is therefore inconsistent as well as being open ended. Presumably the figure of 300 is based on some calculation of homes per hectare and, if so, the word “approximately” would be more appropriate although the 300 figure is flawed as the number of hectares of previously developed land is considerably overstated – see 5. below.
4. Land at Wheatley Campus Para 4.66 page 49
We can find no justification in the National Planning Policy Framework relating to the redevelopment of large sites within the Green Belt for the use of the term “volume” to be taken into account in the determination of any planning application.
5. Policy STRAT10: Land at Wheatley Campus, Oxford Brookes University
It is stated that the existing development footprint is 12 hectares out of a total site area of 22 hectares, namely 54.5%. We can find no evidence that this is the previously developed area and we refer to the attached map (Appendix 1) showing the various land uses on the site. We can only assume that the two uninhabited residential properties, Kortenay and White Cloud, the sports pitches to the north of and adjoining the A40 and the tennis courts and all weather pitch (despite sub paragraph iii) have mistakenly been included in the existing development footprint, the inclusion of which would be detrimental to the openness of the Green Belt. Case Law has determined that “the concept of “openness” … means the state of being free from built development, the absence of buildings – as distinct from the absence of visual impact”.
6. Policy STRAT10: Land at Wheatley Campus, Oxford Brookes University – sub paragraph vii)
There is no reason to restrict the existing main access to the east onto the Waterperry Road to emergency and pedestrian access only. Traffic flow to and from the site should be dissipated as widely as possible and should not be restricted to the western end only.