17/02832/FUL

276 - 280 Banbury Road Oxford Oxfordshire OX2 7ED

23 September 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 original, and revised designs, and the additional documentation now supplied, as follows:

Planning policy issues:

We reiterate the objections previously made, and the justification for them.

Design:

We reiterate the objections previously made, and the justification for them.

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. The assertions contained in the latest transport report are unsubstantiated by any data or analysis of the likely behaviour of hotel visitors in regard to the particular circumstances of Oxford, hence they are of unproven veracity.

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. Furthermore, the data supplied relating to other Easyhotel sites fails to include information highly relevant to users’ behaviour, such as proximity to public car parks, existence and terms of any local Controlled Parking Zones, charging regimes etc.

Despite the close proximity of this site 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 addendum transport report continues to omit any consideration of the baggage characteristics of hotel visitors, and the significance of these to convenience of parking.

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 nothing more than an unsubstantiated assertion, justified by no credible evidence related to the particular circumstances of Oxford and the behavioural characteristics of its visitors.

The latest traffic generation analysis continues to fail to consider properly servicing of the hotel guests. 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 addendum transport report asserts that the arrival of guests by coach is unlikely, but this assertion is not supported by any credible evidence, or consideration of the particular behaviour of visitors to Oxford. No provision has been made for coach drop-off, but disembarkation on Banbury Road would cause totally unacceptable disruption to traffic. 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. We note that the addendum transport report fails to consider or even mention the implications of the implementation of the Oxford Transport Strategy of the Highway Authority.

There are thus a series of safety issues which remain un-addressed 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 and precise terms 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;

The addendum transport report is heavily flawed in many respects:

it is full of assertions on likely behaviour, without credible substantiation;
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 fails to recognise that the CPZ in place provides for visitors to the retail and other businesses, in addition to residents;
it fails to identify the differences in regime imposed by the CPZ on different parts of different streets – for example, in the nearest streets, Lonsdale, Portland and King’s Cross Roads, South Parade and Rogers Street there are at least 8 different control regimes, including substantial locations where free parking for all is permitted between 3.30pm and 11am;
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, and without cost, over the use of remote public car parks;
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 ignores the purpose or rationale for the imposition of the CPZ, in supporting the viability of the commercial and retail activities of Summertown;
it ignores the fact that retail activities continue until late at night, with supermarkets and convenience stores serving, in some cases until 11pm. The transport assessment is thus wrong in suggesting that hotel parking requirements are complementary to other uses;
it ignores the Summertown Farmers Market, operational every Sunday morning, and the traffic and parking issues associated with;
it ignores the fact that Summertown enjoys a vibrant evening and night-time economy, with at least 8 pubs, bars or restaurants;
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);
it relies on assertions relating to the behaviour of this operator to attempt reassurance that the development will not have a significant adverse effect on the social characteristics of the neighbourhood.

The simple inaccuracies contained in the addendum transport report, the inadequacy of the consideration given to parking issues, and the serious adverse social and economic effects of the proposal render it unacceptable.

The current drawings still 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, with their concomitant harm to the social fabric and well-being of the neighbourhood community.