276 - 280 Banbury Road Oxford Oxfordshire OX2 7ED
12 July 2018
Demolition and redevelopment of existing retail office, and residential premises, to provide a mixed-use scheme comprising 4 x units (use classes of either A1,A2,A3 or A4) at ground floor with a 180 bed hotel over three floors above.
We wish to comment on the above application for planning consent, further to our earlier comments on the now-revised design, as follows:
Planning policy issues:
The current Oxford Local Plan (2001 – 2016) is obsolete, is already 2 years out of date, and is due to be superseded within one year by the emerging Local Plan 2016 – 2036. The current obsolete Plan is silent on the designated use of this site, but Policy TA.4 nevertheless states that:
“Planning permission will be granted for development … subject to the following criteria:
… it is acceptable in terms of access, parking, highway safety, traffic generation, pedestrian and cycle movements
… it will not result in an unacceptable level of noise and disturbance to nearby residents.”
We believe that the proposed use and scale of development is in breach of these criteria – it is not acceptable in terms of access, parking arrangements, highway safety, traffic generation, or generation and accommodation of pedestrian and cycle movements.
Since the adoption of the current, obsolete, Local Plan, circumstances relating to the urban development of Oxford have substantially changed, with Oxford now recognised as having the least affordable housing in the country, and the provision of housing now the highest priority for future development. This, revised, proposal restores the existing residential accommodation, but jeopardises the achievement of current objectives to maximise the provision of housing. The latest draft of the emerging Oxford Plan 2036, anticipated to be adopted within a year, addresses the crisis in housing provision much more specifically than its obsolete forerunner, and identifies this location as Site 356. The policy for this site is for development including: “Retail on ground floor, housing, student [accommodation] and office above”; it is clear that a major hotel development is not considered appropriate for this site; consent to such a proposal would thus significantly impede the implementation of emerging policy to prioritise housing, and hence is unsustainable in the terms of the National Planning Policy Framework.
In parallel with the development of the Oxford Local Plan 2016 – 2036, the Summertown St. Margaret’s Neighbourhood Plan is in an advanced state of preparation, and, again, in order to preserve and enhance the character of the area, acceptable uses for the Neighbourhood are identified as housing and small-scale retail and commercial enterprises unlikely to exacerbate traffic congestion and highway safety issues. Although not yet adopted, it must be a material consideration that the Neighbourhood Plan is in existence and represents the considerable analysis of the future development requirements of the Area implicit in the preparation of the Plan. This application makes no mention of the emerging Neighbourhood Plan, but the proposals would be in contravention of draft policies RBC1, RBS2, TRC2, TRC5, TRC6, HOS1, HOS7, and HOS8.
The development of hotel accommodation on this scale at this location is inappropriate; Summertown has a distinct character as the ‘heart’ of a vibrant, primarily residential neighbourhood, and the introduction of a large transient population of visitors at its very core would inevitably erode and damage that character. Easy Hotels report occupancy levels of approximately 80%, suggesting that around 300 hotel guests may be expected at any time. The northern suburbs of Oxford already contain a number of substantial hotel developments, as well as many smaller hotel and bed-and-breakfast establishments providing short-term accommodation, and causing much less harm to the character of the area, both because of the consistency in scale with the predominantly residential development, and because of the smaller numbers of visitors which are accommodated per establishment, and thus introduced into specific locations in the neighbourhood. Whatever the overall need for hotel accommodation in the city, it is unacceptable to further concentrate such development in this area, on the scale proposed. The introduction of what would be the largest hotel in the area by some margin would be severely detrimental to the local character and environment.
The revised design, reflecting the incorporation of replacement housing for that currently existing has, effectively, added a storey to the building. It is extremely regrettable that the applicant has not taken the opportunity to engage with the Oxford Design Review Panel, since the proposed design is little more than a monolithic block, showing little concession to design quality, or appreciation of the sensitivities of the site, such as its location at the transition from the 1970s commercial developments to the south, to the Edwardian, residential-scale architecture to the north. The result is over-bearing on all elevations, with out-of-scale massing, inappropriate to the site. In particular, the façade facing Mayfield Road is now 5 storeys high, and the previous proposal to step back the top (fourth) floor has now been abandoned. The façade has thus effectively increased in height by 2 storeys compared with the previous proposal, resulting in an inevitable ‘canyon’ effect to Mayfield Road, which is of insufficient width to make this acceptable. We consider that the design is now unacceptably over-bearing and unsympathetic to the context and character of the setting.
Parking & traffic issues:
No analysis is provided of the likely motivation for visiting Oxford of intended clients of the proposed hotel, but the transport and parking documentation supplied suggests that it is assumed that there will be a high proportion of single-night stays. Given the attractions of Oxford as a tourist destination, this is erroneous. Data is provided on parking provision at other Easy Hotels, but none reflects a realistic comparator to Oxford; the nearest comparator in size, Luton (still substantially larger than Oxford), clearly generates hotel accommodation demand by the proximity of the major London Airport, i.e. its hotels cater for a different demographic, much less likely to arrive by car than at Summertown. The data supplied can thus have little relevance to this application.
Despite the close proximity to public transport services, these connect only to the city centre or Headington, and to Oxford Parkway station; connections to international airports, for example, are not convenient, especially for clients encumbered by up to 23kg of baggage. The absence of data on the likely motivation of guests for visiting Oxford precludes the making of assumptions on travel modes, but anecdotal evidence suggests that a significant number of visitors combine Oxford with visits to Stratford-on-Avon, or the Cotswolds, for example. The proposal that a majority of hotel guests will not use private cars is unsubstantiated by credible evidence, related to the particular circumstances of Oxford and the behavioural characteristics of its visitors and is, at best, questionable.
The traffic generation analysis fails to consider properly deliveries to and servicing of the hotel, and of the guests of the hotel. A significant proportion of the former will inevitably be made by commercial vehicles and HGVs, whilst, since no food or refreshment facilities are proposed, and given the ‘budget’ designation of the establishment which diminishes the probability of guests patronising local restaurants, it must be expected that online ordering of meals and drink by guests will be a significant factor in traffic generation.
Traffic generation is not only relevant in terms of numbers of vehicles contributed to the already-congested Banbury Road, but also because 50% of access and egress movements will necessitate right turns off one of Oxford’s most congested arteries, with no provision of a dedicated waiting lane, and directly opposite the principal east – west connecting route (South Parade) to Woodstock Road.
The application makes no reference to hotel guests arriving by coach, and no provision appears to have been made for coach drop-off. Dis-embarkation on Banbury Road would cause totally unacceptable disruption to traffic, and since a significant number of visiting coaches to Oxford are foreign-registered, the possibility arises of passengers stepping directly into the traffic stream, with obvious safety consequences. Banbury Road is also designated under the Highway Authority’s current Oxford Transport Strategy to become the route of at least one, possibly two Bus Rapid Transit services, as well as a Cycle Premium Route; this application, likely to inject traffic associated with up to perhaps 300 people into Banbury Road, at one of its most constrained points would seriously jeopardise the feasibility and functioning of the adopted Strategy. There are thus a series of safety issues which are not addressed, as well as the issues of congestion, jeopardy of implementation of adopted transport strategy, air pollution etc. which make this application unacceptable.
Minimal parking provision is proposed for the development, but it is inevitable that a significant number of guests will require parking in the neighbourhood, possible for several days. The identification of sister hotels in other cities fails to include information such as the location of the hotels within the cities concerned, their proximity to public off-street and on-street parking, the costs of such parking, the reasons for guests to visit, the number of guests who arrive by private car, or the locations at which they park. The information is thus irrelevant to this application, and provides no justification for the near-elimination of parking provision in the design proposals.
The parking survey submitted with the revised application defies credibility for a number of reasons:
- it represents only a single snapshot of the current conditions;
- it relates only to certain specific times of day;
- it fails to consider the charges imposed at the public off-street car parks, and the incentive this obviously creates for on-street parking;
- it fails to acknowledge that on-street parking is available much closer to the site than any of the off-street car parks;
- it ignores the fact that the public off-street car parks are intended, for example at Alexandra Park, for the use of recreational users;
- it ignores the effects of the removal of around 30 car parking spaces currently available to staff and customers of the existing retail units, which will not be replaced;
- it fails to identify the differences in regime imposed by the CPZ on different parts of different streets;
- it records available on-street parking at locations as far as 300 metres from the hotel site – unfeasibly remote;
- it fails to acknowledge the obvious preference of hotel guests for parking as close to the hotel as possible;
- it ignores the fact that every hotel guest will be encumbered with baggage;
- it implies that it is acceptable for residents (who have paid a substantial sum for parking permits) to be able only to find parking locations up to 300 metres from their homes;
- it refers to ‘overnight parking’, when, in fact, free parking is available from as early as 3.00pm, and until as late as 11.00am, in certain areas, including those closest to the hotel site;
- it ignores the rationale for the imposition of the CPZ, and that of the ‘free’ periods short-term provision at certain locations, in supporting the viability of the commercial and retail activities of Summertown.;
- and it ignores the assessment made of the capacity of the public off-street car parks in the preparation of the Diamond Place Supplementary Planning Document – part of the current Local Plan (the SPD certainly did not envisage the introduction of a 180-bedroom hotel in Summertown).
The inadequacy of the consideration given to parking issues, and the serious adverse social and economic effects of the proposal render it unacceptable.
Regarding cycle parking, it is clear that little consideration has been given to likely requirements. Particularly in the light of the assertion that many guests will not be car-borne, but also given Oxford’s aspirations as a ‘cycle city’, the stated cycle parking provision is unacceptably low. The drawings fail to identify numbers or detailed arrangements for bike parking, which should differentiate between parking for residents and visitors, parking for hotel guests, parking for customers of the retail units, and parking for employees, all of which should be convenient, secure and covered, and general parking for dockless hire bikes, which could well be attractive to hotel guests.
We would urge refusal of this application on the grounds of failure to comply with policies relating to the use of this site, and the need to prioritise housing development; inconsistency of the use and scale of operation with the character of the neighbourhood; poor design, unsympathetic to the context; significant adverse impact on traffic conditions and highway safety; and serious detrimental impact on the parking arrangements, both off-street and on-street.