West Way Community Concern

Experts’ comments

Page updated 3rd June 2016

New – updated commentary on traffic and parking

Commentaries on : traffic and parking, retail assessment, landscape and visual , wind effects , errors in Mace’s application

See also the WWCC blog for comments from experts and local residents

Other West Way Community Concern documents created and comments received during the consultation on Doric’s planning application, Dec 2014 to Dec 2015 are below.

Botley Character Assessment prepared using the Oxford Character Assessment Toolkit, approved by English Heritage

Summary reports for the Council – November 2014

Our first report focuses on why there has been so much opposition, what local people are concerned about, and what is needed. This report has been sent to Councillors and is available below. Our second report is in progress and will be sent to Councillors in the coming days. That report shows how the planning arguments do not stack up and why the application should be refused.

Report 1: West Way redevelopment: a matter for concern

Report 2: West Way redevelopment – a sustainable development?

Report 3: Character and Visual Impact of West Way Proposal

WWCC’s objections:

WWCC have submitted objections at all stages of the plans. We have made these available below. The current consultation closes on Nov 20th and we will post our final objection here once submitted.

20th November, 2014: Click to read WWCC’s final objection submitted on the amendments to the revised plan on 20th November.

13th October 2014: Click to read WWCC’s additional objection comments on the revised plans submitted on 13th October. Also our further comments on  transport.

June 2014: WWCC comments on the Environmental Impact Assessment:

PDF of WWCC full EIA Comments (file size: 2 MB)

Presentation slides from 21st June public meeting

See below for sections of our EIA comments along with a summary of the chapters.

Also read thestatement from the Church (Church of St Peter and St Paul,North Hinksey & Botley)

March 2014: West Way Community Concern’s objection to the West Way application and supporting documents:

Other comments

Among the local residents, shoppers and businesses who have commented on the proposals there are a number of experts in relevant fields. On this page we have collected extracts from the detailed comments submitted by the some of these experts.

Philip Pullman, Baroness Deech, and many of the experts below have signed an open letter to the Vale, read the letter here.

 Alan Reeve, Reader in Planning and Urban Design, Oxford Brookes University, submitted a 9 page objection to the plans citing ways in which the application fails to conform with 19 policies of the 2011 Local Plan or the National Planning Policy Framework. (VOWH ref 552). As well as his list of 17 grounds for objections, Alan adds:

“As a qualified and experienced urban designer, I am including a detailed critique of the urban design report provided to the local authority by Doric which clearly demonstrates that they have failed to make a competent assessment of either the quality or the needs of the area to which the development relates.”

Alan concludes:
“The report submitted to the vale that purports to provide the urban design case for the proposal is, in my view, deeply flawed, and deliberately misleading. It is poorly written; it provides no evidence for the many claims that it makes about such things as the need for student housing, the need for a large superstore, or the changes to the character and scale of Botley. It deliberately ignores the fact that Botley is, in its planning designation, a Local not a District Centre; and it advocates a scheme which will have seriously negative environmental impacts – particularly in terms of traffic, congestion and a poorer non car environment; and the prosed plans make no attempt to mitigate these environmental impacts.”

Alan Reeve, Reader in Planning and Urban Design, Oxford Brookes University

 

Retired NHS Consultant Psychiatrist Dr. David W. Millard wrote:

“I welcome the small refurbishments that have taken placed in recent weeks. I am, however, profoundly opposed to the inclusion of Field House in the proposal … It is common knowledge among the professionals involved in this area of work probably also among the general public that the forced relocation of residents from such places is regularly followed by an increase among them in physical and mental ill-health and in higher death rates. This is not, however, a vague general impression, but a matter that has been the subject of serious research and the collection of evidence …  In one study … within a year of moving: 38 among 83 of those relocated died compared with 12 of 90 controls … that is, almost half those forced to move died (47%)”

Dr Millard goes on to apply the figures of two of these studies to the residents of Field House and concludes:

“Applying the figures from each of these studies to the 60 residents of Field House, according to the rate found in the first study about 28 would die within a year as a direct result of this enforced relocation; the second study would put the number at 5. In practice, the actual figure would probably fall somewhere between these limits, but both estimates are at least twice as high as the expected death rate if the residents are not moved. It is difficult to reconcile the Council s policy that any development should not cause unacceptable harm to the amenities of nearby residents (VOWH Core Policy 8.iv.) with the eviction of these 60 vulnerable old people from their homes on the site.”

David W Millard, MA, MD, FRCPsych., Emeritus fellow of Green College, Oxford

 

John Cramer, a traffic engineer with over 40 years experience wrote:
“Table 9.1 summarises the Practical Reserve Capacity (PRC) for the base year of 2013. Given that traffic queues each day on West Way, in the am peak and well beyond, it is unlikely that the PRC’s shown in the table can be realised. … In all modelling of traffic capacity individual junctions can be shown to work well but when the network over a wider area is taken into account the capacity is determined by the weakest junction. As a traffic engineer of over 40 years experience dealing with junction design a PRC of 5% or less would be deemed to be unworkable. It would have to be acknowledged that additional improvements would be required or accept that long queues and delays and subsequently heavy congestion. For the proposed year of opening of the development, 2016, PRC’s below 5% are predicted (see Table 9.2) and for the years 2021 and 2026 (see Tables 9.3 and 9.4, respectively) the situation only deteriorates. Paragraph 9.27 acknowledges that there is an increased traffic impact by 2016 with a further increase by 2026. The author refers to these as slight but with the high number of very low or negative PRC’s these cannot be considered to be light. ”

John Cramer

 

Gordon Stokes, a transport academic with over 30 years’ experience wrote in his objection:
“The Transport Assessment is not fit for purpose and should not be regarded as a truthful representation of the likely transport impacts. A series of assumptions display a consistent tendency to underestimate likely traffic impacts, and the forecasts have to be questioned. It is misleading to an extent that the application should be refused on this aspect alone, and it is difficult not to come to the conclusion that it has been designed to give as ‘positive’ a forecast as possible … It is not feasible, with the data provided, to fully re-work the calculations, but I would judge that the underestimate of likely traffic could easily be over 50%. Any Transport Assessment resubmitted for this application should allow for a full audit by independent experts.
… The development amounts to an overprovision of retail offer for an area of Oxford which is geographically constrained and cannot be described as ‘sustainable development’. It could only work with a substantial inflow of shoppers from areas where a car is the only viable means of access, which is contrary to all notions of sustainability in the National Planning Policy Framework (para 34), the saved VOWH policies on retail hierarchy (SC1) and minimising the need to travel (GS10), and the County Local Transport Planning policy SD1. It fails even against Core Policy 8 of the emerging Local Plan 2029, as the proposals are not “appropriately scaled to the role and function of Botley as a Local Service Centre”.

Gordon Stokes. Visiting Research Associate, Visiting Research Associate, University of Oxford & Transport Statistics Users Group

 

Riki Therivel, a sustainability consultant and visiting Professor at Oxford Brookes University who teaches environmental impact assessment MSc and has writtern several books about EIA and given evidence at enquiries, submitted detailed objections in March, June and September including specific comments on the  Environment Impact Assessment.

Riki wrote the following summary of her objections on pollution grounds:
“The proposed development is within 300m of two Air Quality Management Areas, both of which would receive more traffic as a result of the development. The 525 students would all be subject to air pollution levels nearing the legal standards for NO2. Indeed it is difficult to imagine of a clearer case of a new development exposing new residents to poor air quality. The EIS does not take into account stop‐start traffic, people searching for parking spaces if those at the development are full, or air pollution impacts to residents of Westminster Way south of the development. “

She also commented:
“The proposed development is severely out of scale/mass with its location. It would be up to eight storeys tall in an area where most buildings are two storeys tall. It would lead to one side of West Way looking massively discordant with the other side. It would affect people’s views of the hills that contribute to the character of the locality. The proposal’s design is generic, with no link to local distinctiveness, or with the area’s natural, built and historic environment. The EIS has scoped out daylight and sunlight, although several properties would be severely affected by the development in this respect.”

Riki  Therivel, visiting professor, Oxford Brookes University Planning Dept, and partner, Levett-Therivel sustainability consultants

 

Prof. Harry Rutter was a core contributor to the WHO Health Economic Assessment Tool for Walking and Cycling

In his objection to the West Way application he highlights issues for cyclists and pedestrians:
“The development will increase traffic into the area, with additional noise and impact on air quality, both during construction and afterwards, especially at night. Additional traffic will make the environment less appealing for pedestrians and cyclists, and runs counter to the requirements on the council to reduce carbon emissions and promote active travel. The development worsens conditions for cyclists and pedestrians in other ways too, creating a large obstacle to free movement in the area.”
In his general comments Prof Rutter says:
“This development would have a significant negative impact on the area, in terms of visual impact, traffic generation, and sustainability. The development will result in loss of an important local facility, including shops, dentist, hairdresser, etc and the hub of our community. Local independent businesses will close, losing important social and economic links to the local community. The subsequent imposition of the kinds of chain stores that are seen throughout Britain will destroy the individual local character of the area, replacing it with a ‘clone Britain’ appearance, and siphoning money out of the local economy.”
He concludes:
“I strongly object to the proposed development. The planning application should be refused, and only reconsidered if any new application is of a scale and appearance that matches the local area and would support local residents. The shops and services should be there to provide amenities to local residents, not compete with Oxford to bring in people from further afield. I trust that Vale DC will demonstrate its response to local democracy and reject the proposal.”

Prof. Harry Rutter, London School of Hygiene and Tropical Medicine, MA MB BChir MSc PGDipLATHE FFPH FRCPEdin

 

 

Baroness Ruth Deech, DBE, cross-bencher in the House of Lords, academic, lawyer and bioethicist is a former Principal of St Anne’s College, Oxford and lives in the Botley area. She has written an objection to the application on a number of policy issues.
Baroness Deech writes:
The Vale’s own Policy GS5 of the Local Plan states that new developments should not cause harm to local facilities or the quality of environment. The plans submitted by Doric will inevitably cause the loss of thriving small businesses which have served the surrounding area very efficiently. Their replacement by large chains will not serve to encourage healthy eating or diversity or local business enterprise; the shopping centre would send a message to small business that they are not wanted. The plans run counter to national ambitions to revive High Street shopping (the Portas report). “
She concludes:
“The scale of the development is disproportionate and unattractive, the change in commercial activity is unwanted and detrimental to the environment; it would harm the neighbouring residents and make the life of all, especially the elerly, a lot more difficult. The plan conflicts with policies GS1, GS5, GS10, CF1, DC1, DC6, DC9, S1, S12, H10 and T1 of the Local Plan 2011. I object to every aspect of the plan and the application should be refused as contrary to the Vale’s policies.”

Baroness Deech of Cumnor

 

Jon Rowland concluded in his objection:
“ … as a Chair of a Design Review Panel my opinion would have been that this was neither a good, outstanding or innovative design that would help raise the standard of design more generally in the area; and Botley residents (and the VOWHDC) care about the quality of their environment. This scheme should be setting high design standards for new development in Botley, and it fails to do this.
Permission for the proposed development should be refused on the basis of poor design that fails to take the opportunities available for improving the character and quality of this area of Botley and the way it functions. CABE has said; Ask “is the design good enough to approve?” rather than “is it bad enough to refuse?” I consider this an inappropriate and poorly designed development and not good enough to approve, and as such should be rejected.”
Jon Rowland, Director, Jon Rowland Urban Design

 

 Chartered Surveyor, Edwin Macadam, wrote in his third submission on the application:

“The revised proposals put in by Doric, or those representing them, show little regard to local opinion and comment, and show that neither they, or the Council as the authority who purport to represent the inhabitants of the area most directly concerned by their proposals, have listened to the primary matters of concern voiced by the several hundred – indeed over one thousand – of those who will be displaced or seriously disadvantaged by the gross enormity of what is seemingly being planned with the encouragement of the local authority …
“The application proposes an unacceptable form of development that would adversely affect the vitality of the local service centre and cause significant detriment to the amenities of neighbouring properties. It would be in direct conflict with policies GS1, GS5, GS10, CF1, DC1, DC6, DC9, S1, S12, H10 and T1 of the Vale of White Horse Local Plan 2011 …
“Yes, changes are necessary to the shopping area but not in the way suggested, with a general feeling of being ‘bulldozed’ into submission.”
Edwin M Laming Macadam, FRICS FAAV

 

Oxfordshire Architectural and Historical Society submitted a lengthy objection including coverage of the impact on views:

“The proposed development would be visible as part of the backdrop the the City as seen from South Park (one of the key view cones of Oxford).This relatively close view is probably one of the most visited and amongst the most famous, being commonly represented in historic prints and paintings of Oxford, some by well known artists.

“From different parts of South Park, especially higher or lower areas, the view of the development would vary, but would include places where it would be visible breaking the skyline between and/or behind the famous spires and towers.”

They followed up in June with comments on the EIA including the following:

“In our original submission of 23rd April 2014 we set out in some detail how various notification procedures and significant heritage aspects of the EIA should be approached to ensure that the Council can adequately ensure that its statutory duties under the 1990 Planning (Listed Buildings and Conservation Areas) Act regarding cases that affect the setting of listed buildings and/or the character or appearance of conservation areas.
We are deeply disappointed that, as far as we can tell, neither has been addressed. … The EIA has not adopted an approach even remotely like that which we advocated to ensure that the determination of the application would be properly informed about heritage setting and character issues. The two heritage reports have not been updated from those originally submitted, and neither deals these issues with the setting of key buildings in Oxford. The heritage chapter of the EIA not only fails to address setting issues but also fails to address the principles of Conservation Principles to assess communal values (very evident in responses to the original consultation). The assessment that recording action would reduce the significance of the Elms Parade arcade (as if this made it more acceptable) is contrary to NPPF para 141. …

All-in-all this is a thoroughly incomplete and inadequate assessment of key setting issues – not helped by the failure of these issues to be identified in the EIA screening or any formal scoping. Our own assessment is far from complete but illustrates the issues. In the light of this, and the absence of any reconsideration of other heritage aspects, we believe that ALL our original comments of 23rd April 2014 including its appendix still stand, as reproduced below. We reiterate our strong OBJECTION to the scheme.”

 

Oxford Preservation Trust in their latest submission stated:

“Having considered the new information and conclusions we remain extremely disappointed and gravely concerned that the potential adverse effects on the local character of Botley and of views in and out of Oxford of a scheme of this size continue to be considerably underplayed.”

They commissioned a review by  Chartered landscape architect Jeremy Smith of SLR consulting  who agreed that the visual impacts were underestimated and:

“taken as a whole these effects do not lead logically to the conclusion that there would be no significant effects to general visual amenity as set out in Paragraph 7.288” contrary to Doric’s claim.

Oxford Preservation Trust continue to object, stating “We would urge the Vale of White Horse District Council to demand a fuller analysis of the environmental impact given the scale and potential harm that such a massive development could have on both Botley and the city of Oxford.”

 

Oxford City Council‘s brief summary of their objection:

“The City Council consider that there are a number of adverse impacts associated with this proposed development and therefore wish to object to this proposed development on the grounds of the scale of the development; new land uses proposed; potential traffic generation; and cumulative environmental impacts on Oxford.”

 

North Hinksey Parish Council submitted comments and objections in April, June, September and October in response to the various stages of consultation. In October their introduction states:

“Despite a number of significant changes, we believe that the amended plans submitted in September 2014 are overall on too large a scale, will have a detrimental effect on the character of the area and add to severe existing traffic problems.”

Their response repeats the material planning grounds for objections and also comment on the integrity of the data:

“Further to the above objections relating to specific policies in the Vale of White Horse Local Plan 2011 we also wish to make clear our serious concerns regarding missing reports, conflicting data within the amended documentation and the overall issue of data integrity.”

They on inconsistencies and unrealistic  estimates in the transport assessment andr the retail gravity model, concluding that:

“If Doric’s estimates for (a) and (b) are assumed to be realistic, and both remain as previously tated (the most reasonable assumption) then the total value of the trade diversion trips would need to decrease significantly, leading to a total convenience goods sales value for the new food store of around 65% of the original stated target of £35.6m.”

 

Cumnor Parish Council is also a statutory consultee and has submitted responses at each stage. In the latest response they criticise the way Doric has presented their response to feedback from the Design Panel as opposed to how local residents and their representatives’ feedback is addressed:

“By laying out the report in this way, the impression is created that the responses of local residents, as represented by WWCC, and of their elected representatives, CPC and NHPC, are of secondary value. This is unfortunate. It is the local residents who will be users of and who will have to live with the end result of any development on this site, and it is absolutely crucial that their views are given considered attention.

The applicant is seeking to create the impression that the content and overall function of the proposal is a given, and that all that now needs to be addressed is the fine tuning of how it will look. CPC takes a different view: namely that this is a once in a generation opportunity to redevelop the site, consequently it is essential that the proposal shall sit comfortably in its setting. It is therefore the nature, scale and content of any redevelopment that is at issue.

Sadly this concern receives no serious response in the applicant’s revised proposal; indeed they appear not to understand the issue. The scale of the proposed development is simply avoided in these Amended Details, and it is this perhaps, more than anything, which is the major concern for the vast majority of local residents and their elected representatives. The applicant merely says, Appendix 11.1, p.1: “As a smaller development was not considered by the applicant as representing a viable option for the site, no such plans were drawn up that could be realistically considered in the ES”. This cursory comment on the part of the applicant is unacceptable.”