17/02832/FUL

276 - 280 Banbury Road Oxford Oxfordshire OX2 7ED

10 December 2017

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.

This application proposes the removal of at least 5 existing residential dwellings, in an area highly appropriate for residential development. The draft Summertown St Margaret’s Neighbourhood Plan, currently in preparation and therefore a material consideration, proposes housing and retail uses for this site. Likewise, the last ‘Preferred Options’ draft of the emerging Oxford Plan 2036 identifies this location as Site 356, having development potential for: “Retail on ground floor, housing, student and office above”; it is thus clearly considered, rightly, that whatever its merits for hotel development, housing is the priority and that hotel uses have not been considered appropriate. The crisis in housing prevailing in Oxford should dictate that the prime opportunity represented by this site to make a substantial contribution to meeting housing needs should not be lost by the granting of consent to this application, particularly in the face of current and emerging policy considerations.

The development of hotel accommodation on this scale at this location is inappropriate; Summertown has a distinct character as the ‘heart’ of a vibrant residential neighbourhood, and the introduction of a large transient population of visitors at its very core would inevitably erode and damage that character.

The northern suburbs of Oxford already contain a number of substantial hotel developments, and face considerable pressure for their enlargement. In addition, there are many smaller hotel and bed-and-breakfast establishments which provide a significant volume of accommodation, whilst having a much less damaging effect on the character of the area. Whatever the overall need for hotel accommodation in the city, it is unacceptable to further concentrate such development in this area. 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.

Despite the close proximity to public transport services, it is inevitable that a high proportion of guests will arrive and depart by motor vehicle, whether private car or taxi, and this is likely to exacerbate the already-unacceptable levels of congestion and air pollution on Banbury Road.

Minimal parking provision is proposed for the development, but it is also inevitable that a significant number of guests will require parking in the neighbourhood, possible for several days; the current CPZ already operates at capacity, and makes no provision for non-residents staying longer that 2 or 3 hours.

In fact, there are a number of locations where stays up to 2 or 3 hours are permitted, within a restricted daytime period of, typically, 08.00am to 6.30pm. These areas contribute to the vitality of the retail centre, by allowing short-stay parking for non-residents. However, the lack of restriction of 2 or 3 hours effectively extends the unrestricted, overnight period from 03.30pm to 11.00am. This would be very compatible with hotel check-in and check-out times, for car-borne guests. However, such use would severely harm the intended purpose of maintaining the viability of the Summertown commercial centre, and would seriously inconvenience local residents by taking up overnight parking capacity.

Additionally, increased pressure would be put on the public car parks at Diamond Place and elsewhere, which are not currently designed for an influx of new users such as this development might generate. The current Supplementary Planning Document for this area makes no provision in discussing the retention of public car parking for the demand potentially generated by a 180-bed room hotel in the neighbourhood.

In addition to traffic generated by guests and staff, a hotel of this size will require a considerable volume of servicing, inevitably largely by HGVs. Any increase in traffic, especially of this nature, will have a serious adverse effect on the character of the neighbourhood, on congestion and on air quality.

The Travel Plan Measures document submitted is largely generic and makes no attempt to quantify traffic generation or mode, or likely parking requirements. It is thus wholly inadequate is assessing the transport impacts of the proposed development.

Design details:

For a ‘cycle city’ such as Oxford, the stated cycle parking provision is absurdly low, and there is no indication of how the stated numbers of machines could be accommodated and accessed within the designated spaces. In addition to generous provision for both staff working in the retail units and for clientele, there should be facilities available for the considerable number of staff working on the premises, and for hotel guests; even if the number of guests arriving by bicycle may be small, it is highly likely that visits to the city centre and elsewhere by bicycle would be regarded as an attractive proposition, particularly in view of the fast-growing bike-hire phenomenon. Much more cycle parking, secure, protected and easily accessible should be provided.
The Acoustic Consultancy Report (ACR) provided identifies that in order to meet acceptable criteria for noise intrusion, ventilation should not be provided by opening windows, or ventilators in the external facades, and indeed, none are shown on elevation drawings. The implication of this is that mechanical ventilation will be installed, though the ACR states: ”At this stage of the development, no information is available about the future fixed plant installations …”. Indeed, no information on mechanical and electrical plant installations has been provided, but limited accommodation for such plant is shown. The number, location and dimensions of louvres shown on elevation drawing appears incompatible with plant providing HVCA services to 180 bedrooms and common areas. It thus appears likely that significant alterations to the appearance of the building may be expected when service installations are developed. Additionally, whilst no roof-mounted installations are shown, the maintenance of a clear roof profile should be made a condition of the granting of any consent.

We object to this proposal on the grounds of:

failure to comply with current and emerging policies on housing provision, and the use of this site
inappropriate nature of the use proposed for this location,
likely harm to the character of the neighbourhood,
inadequacy of the traffic impact assessment,
likely effect on congestion, traffic nuisance and air quality,
detrimental effects on both on-street and public car parking provision in the neighbourhood,
detrimental effects on residential amenity and commercial activity,
inadequacy of cycle parking provision and details,
absence of any details of plant installations, and their implications for the appearance of the building and on noise generation
implausible representation of likely actual appearance of the elevations of the building.

We would urge refusal on these grounds