Central Conservation Area – our Response

Comments on the draft Conservation Area Appraisal

29 October 2018

In October Oxford City Council published a draft Oxford Central Conservation Area Appraisal and invited public comments and feedback. The draft Appraisal was prepared jointly by Oxford City Council and Alan Baxter, an engineering and urban design company. We are disappointed with the draft document; we believe it has many shortcomings as set out in our response below which was sent to the Council on 26 October. The original consultation documents are available here.

Oxford Civic Society welcomes the decision to appraise the Central Conservation Area for the first time. It is the jewel in the City of Oxford’s crown and important for all the people of Oxford and countless visitors from around the world. Its importance cannot be overstated.

The lavishly illustrated report issued for consultation is unfortunately incomplete in that arguably the most important sections concerning the opportunities and threats and recommendations for future planning policy are missing. Also, as a vehicle for public consultation, the report is unfortunately not fit for purpose in that it is only available on-line (except for a few hard copies available in public libraries). It is extremely difficult to use on-line because the maps are too small and the need to display maps alongside text even defeats users of large screen computers. Professionals have told us that it is exceedingly difficult to work with. It is regrettable that more hard copies were not made available if only to a limited number of community groups. The public drop-in sessions organised by City Council staff were welcome, but they did not overcome the obstacles described above.

We commend the excellent response from the St John Street Area Residents’ Association whose work was only possible because they went to the trouble of creating a hard copy to work on. We hope that their detailed response will be studied carefully.

The consultants’ report performs a valuable service in documenting the present state of the Conservation Area. However, it tends to view the Conservation Area through rose-tinted spectacles. For example, St Giles is optimistically described as a “public space” (whereas one Society member described it as seeming like a combination of car park and landing strip for small aircraft!); and the “modest Nineteenth Century buildings” in Little Clarendon Street occupy a small fraction of the street which is dominated by mainly undistinguished modern buildings. There are significant numbers of other such examples. We hope that the missing sections on opportunities and threats will put right this lack of balance between the positive and the negatives.

It is puzzling that the geographical coverage of the Conservation Area has not been discussed, which should surely be the starting point for any appraisal. There are substantial “holes” in the Conservation Area which are not subject to the restraints of conservation planning policies, yet developments within these “holes” have a significant effect on the Conservation Area itself.

Despite these shortcomings, the report does perform a useful service in identifying so-called opportunity sites where undistinguished buildings may in due course be replaced. This serves as a potentially useful record for the public to be aware of potential threats to the Conservation Area. The City’s planning policies need to be sufficiently robust to ensure that replacement buildings (or spaces) make a positive contribution to the Conservation Area and are of higher quality than those they replace.

One of the problems of attempting to appraise a very large Conservation Area is how to divide it into smaller geographically coherent sub-sections that can be analysed individually without losing sight of the whole. The report uses “character zones” for this purpose but the analysis is not uniformly thorough, and the maps are too small to see exactly where one zone ends and another begins. Even the authors have been challenged as they have included some streets in one zone which are actually in another!

The concept of “zone” breaks down completely in the case of the “University Zone” which consists of a wide scattering of sites across the Conservation Area. The “Colleges Zone” is also a scattering of sites that should have been considered in relation to their non-college surroundings. This treatment of the University and Colleges implies a “town v gown” approach which is unfortunate. Surely the academic sites should be firmly located in the geographical zone in which they are located and discussed in that context?

It is disappointing that arguably the most significant secular, non-academic feature of the Conservation Area, the Covered Market, is given such cursory attention: another example, perhaps, of the rose-tinted approach! Other areas of the Conservation Area which deserve more attention in the report include the controversy over building heights (where the Civic Society has advocated policies which allow greater flexibility but with regard to preserving important views and street scenes); the protection of key street frontages and road surfaces; the implications of huge influxes of tourists and their buses; and the decline of retail businesses which calls for an imaginative long term policy on the rehabilitation of the affected streets. Perhaps some of these issues will be picked up in the missing sections of the report: we hope so.