Westway Objections in full
Planning application reference: P13/V2733/FUL
Demolition of a mix of existing buildings and the erection of mixed use development comprising retail, restaurants and cafes, offices, hotel, student accommodation and ancillary facilities, 33 apartments, replacement vicarage, library and place of worship (Baptist Church), health centre, cinema, gymnasium, covered car parking and access, public square, landscaping and associated works.
We submitted comments in March 2014 on the proposals to redevelop this site, and, following the submission of amended proposals we wish to comment further on the application for planning consent, as follows:
Oxford Civic Society is a non-profit making voluntary society with nearly 1,000 members dedicated to improving Oxford and its region for people to live, work and relax in. ‘Oxford’ in this context refers to the main built-up area of the city and to adjacent settlements such as Botley which are integral to its form and functioning, not merely to the administrative entity. Our aim is to ensure a sustainable, well-adjusted physical and community infrastructure that all citizens can benefit from now and in the future.
Summary of Objection
The Society supports VOWH District Council in its aspirations for ‘Botley Central Area’ as contained in Core Policy 8 of the draft Local Plan 2029 Part One published in February 2013. We would acknowledge that parts of the site which it is proposed to redevelop are currently tired and in need of regeneration. The alterations now made to the earlier proposals for redevelopment constitute relatively minor improvements; the scale of the development remains unnecessarily large and it would have undoubted adverse effects on the immediate neighbourhood as well as the surrounding area, in conflict with the requirements of the National Planning Policy Framework. We do not consider that the current application fulfils the criteria contained in Policy 8 of the draft Local Plan and therefore we conclude that the application should be refused.
We would still like to see a revised scheme brought forward more appropriate to the local role of the centre and the character of the neighbourhood (hence smaller in content, extent and physical bulk) and which specifically:
- excluded the cinema and reduced the scale of the superstore and student accommodation (and as a corollary the size of the car park)
- provided a mix of residential content
- retained the Elms Parade shops and Field House
- incorporated a car park management strategy, travel plan and CPZ for the surrounding area which together promoted the use of sustainable travel modes and safeguarded the amenities of local residents
- was developed in cooperation with local communities and in recognition of the policies not only promoted in the VWOHDC Local Plan, but those of the adopted Local Plan of Oxford City Council which have clear relevance to this location, in recognition of the NPPF statutory requirement for cooperation between planning authorities.
Details of Objection
Botley as a local centre
We have previously stated, and continue to reiterate that the principal and overarching source of our objection relates to criterion (i) in Core Policy 8, viz that
“taken as a whole, the proposals support and are appropriately scaled to the role and function of Botley as a Local Service Centre providing a well-integrated mix of shops and services to meet day-to-day shopping needs of the local area”.
We infer ‘local’ to mean serving the immediate locality within convenient walking distance, i.e. the areas of Botley, Elms Rise, Cumnor Hill, Dean Court, North Hinksey and Botley Road for which the centre is very well-placed. The current application is plainly designed to fulfil a larger, and in our view inappropriate, role encapsulated in references to it as a ‘district centre’ in the supporting documentation. The resulting scale of physical development is out of character with its surroundings whilst the volume of traffic generated conflicts with the principles of sustainable development and will worsen traffic and environmental conditions.
Botley does not constitute a ‘district’ in the normal sense of the word applied to urbanised areas. Unlike Headington and Cowley for example it is not a contiguous part of a larger suburban area. Rather, it is almost entirely surrounded by the Thames floodplain to the east and open countryside to the north, west and south. Hence, beyond the immediate locality there is a minimum distance of three miles or so to the nearest residential areas such as North and South Oxford and Kennington. These places are not directly accessible to Botley except by private car and even then access is only possible by using the notoriously congested Botley Road or the Ring Road and A34.
To attempt to develop Botley centre on a scale which is dependent commercially on serving this wider catchment therefore conflicts with the principle contained in paragraph 34 of the National Planning Policy Framework:
“Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable modes can be maximised”
Following criticisms of the first Transport Assessment (TA) carried out for this application, a revised TA has now been submitted. Unfortunately, the latest TA is as flawed as the previous assessment. Some of the errors in the assessment are as follows:
- The basis of the assumptions that 36% – 41% of traffic visiting the development in order to use the supermarket from the immediate area is at odds with national statistics and makes no allowance for the local situation, demographics and connectivity. It is not credible that nearly one trip per day will be made by every single local resident.
- The volume of traffic using Westminster Way continues to be underestimated, since the obviousness (indeed, the identification by satnav systems) of this as a ‘short cut’ for northbound A34 local traffic is not acknowledged.
- Traffic data is derived from figures which do not represent daily peaks (e.g. by not using data from worst-case days), leading to an assessment of volumes of generated traffic perhaps 20% lower in some cases than is likely.
- The assessment of linked trips is based on data selected from sites not sharing characteristics with Botley, and reaches the implausible conclusion that at certain times fewer trips will be generated by all the retail operations combined than by the supermarket alone.
- Data for assessing likely ‘passing by’ visits to the site are selected from locations dissimilar to Botley. The precise position of the Botley development relative to the principal road network makes the likely proportion of such traffic much smaller than is concluded.
- The volumes of traffic that it is assumed will use the A420 and Cumnor Hill and will visit from destinations like Cowley and Headington via Oxford City Centre do not acknowledge local conditions and are unrealistic.
- The TA makes unrealistic assumptions regarding the potential for ‘existing’ (pre- redevelopment) traffic assuming full occupation of commercial space, and regarding the proportion of existing traffic passing the site but not visiting or generated by it. It thus substantially over-estimates the pre-development condition, and hence the effects of likely newly-generated traffic.
An independent review of the effects of these errors concludes that traffic volumes have generally been under-estimated by perhaps 50%; the adverse effects of traffic congestion and impaired air quality are thus likely to be very much higher than suggested by the current Transport Assessment.
The inclusion of a six-screen cinema is inappropriate for a local centre, serving a predominantly residential neighbourhood, especially given the existing and proposed facilities in nearby Oxford City Centre. Few cinema goers living in the projected catchment area would have their existing travel time or distance significantly reduced as a result of the development and some patronage would be lost to the city centre outlets. The bulk of the Vale District would remain essentially unserved, except by use of a car. The proposed development at Botley would undermine the case for a cinema in the main centre of the District Council, at Abingdon which is better located in relation to the present unserved area and accessible to more people without the use of a car. The inclusion of the cinema thus undermines the viability of more-appropriately located provision in Abingdon and in Oxford City Centre, as well as being dependent for viability on car-borne transport.
Mix of uses
Criterion (ii) of Core Policy 8 of the VOWHDC draft Local Plan asks that “effective and proportionate use is made of development potential above ground level and on more peripheral parts of the site for a mix of uses including, but not limited to, office, community, residential, hotel and leisure activities”
The very large amount of student accommodation within the proposed development on the one hand and the absence of any ordinary residential use on the other (except the small replacement for Sovereign Housing) is particularly unfortunate in the light of the latest Strategic Housing Market Assessment which suggests a requirement within Vale of White Horse district alone for 1028 new homes per year from 2011 to 3031. The redevelopment of parts of this site would provide an excellent opportunity to contribute to this requirement in an already predominantly residential location, contiguous with existing urban development with good amenities and access by public transport. The current proposal ignores this opportunity completely and therefore imposes additional pressure to construct housing elsewhere, in less suitable locations. The monopolisation of the residential provision of this development by student accommodation does not deliver a social mix or a stable community with ‘ownership’ of the neighbourhood, and does nothing to contribute to the provision of family and affordable housing.
The fact that the student accommodation is not being built to meet the requirements of a particular educational institution raises additional concerns about its day to day management. We note that none of the established major educational establishments for which Oxford is famous have expressed interest in the utilisation of the student housing proposed in this development. It is not clear what controls, if any, would govern occupants and it is possible that a high turnover of relatively short lets to a disparate range of users would prevail. The introduction of such a high proportion of ‘transient’ residents into what is currently a vibrant and engaged community is likely to be socially disruptive and will erode the coherence of the local community.
Design, character, appearance and residential amenity
Criterion (iv) of Core Policy 8 of the draft VWHDC Local Plan states that “proposals will not harm the character or appearance of the Botley central area, and will not cause unacceptable harm to the amenities of nearby residents”
The character and appearance of the Botley central area are defined by the Elms Parade shops and their relationship with the surrounding residential streets. This is not simply an architectural definition, but one of the client demographic as well. The current proposal involves not only harming the character and appearance of the Botley central area, but its complete destruction. Replacement with premises of a completely different scale and character cannot constitute conformity to the intentions of the draft policies established for this area.
The South East Regional Design Review Panel made a critical assessment of the design of the original proposals; the altered proposals make architectural changes, but many of the concerns expressed have not been addressed in any meaningful fashion:
– the scale of the development is still excessive (only minor alterations have been made), and comprehensive 3D modelling as suggested has not been carried out to facilitate proper assessment.
- At the NE corner it was suggested that a more ‘residential’ entrance to the development should be provided; the current proposal falls a long way short of this.
- The proposals fail to recognise the essentially residential character of the neighbourhood, and the need to develop solutions which are appropriate to this characterisation.
- The architecture should be in keeping with the ‘restrained’ style of the local vernacular
- The excessive size of the proposed supermarket constrains other aspects of the design unreasonably; the reduction in the size of this unit has been minimal
Examples of some of the unacceptably poor design of the current proposals are:
- The piazza is too small to create a truly functional public space, is too ‘one-sided’, and has poor and uninviting access
- The proximity and scale of the buildings adjacent to Arthray Road remain over-powering to the existing residential properties and destructive of the character of the road
- The proposed buildings fronting West Way destroy the architectural and heritage merits of the existing Elms Parade; they are too close to the traffic on West Way to make an attractive environment
- There is no coherent vision for West Way, hence no attempt at integrating the character of the neighbourhood across the road, or mitigating the divisive effects of the road on the community
- The setting of the church of St Peter and St Paul, is not enhanced; the proposals for the incorporation of the Baptist Church have no functional or aesthetic merit
- The design of the proposed steps represent a deterrent, rather than an invitation to the interior of the development
Reference has already been made to the inadequacy of the Transport Assessment, but notwithstanding these faults, it is clear that even the increase in traffic volumes presented therein would constitute serious harm to the amenities of local residents, in the form of environmental degradation, noise and air pollution.
Access and Car Parking
Criterion (v) of Core Policy 8 requires that “proposals for the site are prepared through a comprehensive master planning process providing an integrated solution to site access, servicing and sufficient car parking whilst prioritising the pedestrian customer environment”.
Despite amendment, there remain inconsistencies in the Transport Assessment on the subject of parking provision and management. It is still not credible to suggest that parking will not spill over into surrounding streets and at the same time to claim that restraint is being applied which will encourage the use of alternative modes.
We are concerned that the proposed regime for parking provision and management would not meet the reasonable requirements of all occupants and visitors to the development and would involve displacement of commuters and other longer stay parkers into the surrounding streets, exacerbating problems which are known to exist already. We would also question whether the proposed regime makes the best possible contribution to wider transport objectives in discouraging car commuting to accessible locations and in promoting the use of more sustainable modes.
We believe that redevelopment of the Botley centre provides the opportunity for a comprehensive review of parking arrangements in the area (including the business-related parking at Seacourt and North Hinksey) in order to achieve a satisfactory outcome overall. By way of comparison it is worth noting that the other suburban centres in the Oxford area (Summertown, Headington and Cowley) all operate a scale of charges which encourages use of alternative modes, balances supply and demand and provides for a range of requirements as to length of stay. Summertown and Headington are also situated within Controlled Parking Zones which counter displacement problems which might otherwise arise. We believe that a similar regime is likely to be necessary in the Botley area.
We support the principle of low or no-car ownership within the residential component of the development but doubt whether the current aspiration in relation to the student accommodation could be made to work in practice in the absence of a CPZ. We think that this principle would be enhanced by inclusion of a car club and bicycle hire scheme as part of the proposed Travel Plan – facilities which would also be of benefit to other businesses and residents in the locality.
Coordination with the Oxford Local Plan
In geographic, social and economic terms, the location of this development is irrefutably connected directly with the culture, society and economy of the city of Oxford. It is therefore no more than clear common sense that the proposals for development here should consider relevant policies of Oxford City Council, as well as those of VWHDC.
I this case, clear common sense is reinforced by an important element of the National Planning Policy Framework. This is the requirement that adjacent Local Authorities cooperate in preparing and implementing Local Plans.
It will thus be a statutory requirement that VWHDC cooperate with Oxford City Council in reaching a decision on this application. It is therefore necessary that the current development proposals should be considered for conformity not only with the provisions of the National Planning Policy Framework and the policies of the VWHDC draft Local Plan, but with those relevant policies of the adopted Local Plan of Oxford City Council.
Perhaps most critically, Oxford has a world-renowned reputation for its historic environment and its setting. The latter includes not just the natural environment of its surroundings, but the diverse and individual social and architectural character of its suburbs and the towns and villages of its immediate region, and the views of the city therefrom.
The Strategic Housing Market Assessment referred to earlier suggests, in addition to the needs of the VWHDC administrative area, 28,000 new homes serving Oxford city by 2031 – well beyond the possibilities of provision by Oxford City Council alone. To ensure that the economic development of the immediate region is not constrained by housing shortage, it will be essential that there is cooperation between authorities in making provision, in the most appropriate locations. This proposal fails to give any recognition to the need for provision of family housing in both the Vale of White Horse and Oxford City districts, the obligation on Local Authorities to cooperate in this regard, or the eminent suitability of the site for such provision.
We have the greatest concern that the proposals for the development of this site pay no regard to the policies adopted by Oxford City Council relating, inter alia to:
- the setting of the city
- the views of the city from the surrounding
- the historic built environment
- the heritage of all parts of the conurbation
- the relationship of surrounding suburbs and local retail, leisure and social facilities to the city centre amenities
- the reduction of motor traffic
- the management of air quality
- the provision of family housing
We note that Oxford City Council has objected to this application, based on earlier proposals. We do not see that the amendments now suggested address adequately the City Council’s grounds for objection, hence we would anticipate that the objection will be sustained, and we would continue to endorse the objection.
We continue to object to this application on the grounds that it is likely to cause significant harm to the environment, the social amenity of the neighbourhood and its economy.
The proposals would:
- generate considerable volumes of additional traffic
- exacerbate existing problems of air pollution and corresponding impaired health
- cause considerably more noise pollution
- lead to additional congestion on surrounding strategic highways, access roads and residential streets
- increased journey times and ease of access to commercial premises and centres of employment
- destroy the existing architectural character of the neighbourhood
- erode and over-power the essentially residential nature of the surroundings
- create new buildings of a scale that is inappropriate, impose designs that are sterile, and deliver a built environment that is devoid of character
- make retail provision on a scale inappropriate to the neighbourhood and at odds with its cultural and economic role
- put the viability and/or probability of provision of better-located facilities in Abingdon and Oxford town and district centres at risk
- do nothing to address the most pressing need for provision of additional family housing
- erode the cohesion of the community and local society
- fail to conform to the requirements of the National Planning Policy Framework in regard to sustainability
- ignore the requirements of the adjacent community of Oxford and the statutory requirement for cooperation between planning authorities
We therefore urge that this application be refused.
Chairman, Oxford Civic Society