Shaviram Group June 2021
Planning Statement
Thornhill Park, London Road, Headington, Oxford
savills.co.uk
Planning Statement Thornhill Park, London Road, Headington, Oxford
Contents 1. Introduction 1 2. The Site and its surroundings 3 3. Planning history 5 4. The proposed development 6 5. Statement of Community Involvement 10 6. The Development Plan 17 7. Planning assessment 22 8. Planning balance and conclusions 48 Appendices 50 Appendix 1.0 EIA Screening Opinion 51
Project: Thornhill Park, Headington Client: Shaviram Group Job Number: OXPL410487 Status: FINAL VERSION
Document Checking:
Prepared by: JA ASSOCIATE DIRECTOR PLANNING MAY 2021
Checked by: RAS DIRECTOR PLANNING JUNE 2021
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Planning Statement Thornhill Park, London Road, Headington, Oxford
1. Introduction
1.1. This Planning Statement has been prepared on behalf of the Shaviram Group, and its subsidiaries Sandhills Development Ltd. and Downside Homes Ltd., hereafter referred to as 'the Applicant'.
1.2. It supports the submission of a full planning application to Oxford City Council for the following:
“Development of 402 apartments (Class C3), a 133 bed hotel (Class C1), employment provision in the form of an Innovation Centre, with additional mixed use accommodation to include office space, gym, café and restaurant (all within Class E), public open space, associated landscaping and the provision of a new vehicular access onto the A40.”
The proposed development is located on approximately 3.34 hectares (ha) of land at Thornhill Park, on the south side of London Road, Headington, Oxford (hereafter 'the Site'). The extent of the Site is edged in red on the accompanying existing site plan, drawing reference (01397E_JTP_SP00).
1.3. The Site is allocated for residential-led mixed use development in the adopted Oxford City Local Plan 2036, as set out under Policy SP47.
The Planning Application Submission
1.4. This Planning Statement draws upon the findings of various technical reports and drawings that form part of this submission, and should be read in conjunction with the accompanying application material in order to provide a comprehensive understanding of the proposal and its associated benefits.
1.5. This planning application is accompanied by the following technical documents:
. Application forms & ownership certificate, by Savills; . Planning Statement (this document), incorporating Affordable Housing Statement, by Savills; . Statement of Community Involvement, by Savills (also incorporated in this Planning Statement); . Community Infrastructure Levy form, by Savills; . Health Impact Assessment, by Savills; . Site plans, elevations, sections, overall masterplan and CGIs, by JTP; . Design and Access Statement (DAS), including Crime Reduction Statement, by JTP; . Archaeological Assessment, by Cotswold Archaeology; . Heritage Impact Assessment & Statement, by Cotswold Archaeology; . Landscape and Visual Impact Assessment, by BMD; . Landscaping Strategy and Proposals, by BMD; . Ecology Surveys & Assessment, and Biodiversity Enhancement Plan, by Greengage; . Arboricultural Impact Assessment, by Lockhart Garratt; . Flood Risk Assessment & Drainage Strategy, by Cole Easdon; . Transport Assessment & Travel Plan, by Cole Easdon;
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Planning Statement Thornhill Park, London Road, Headington, Oxford
. Energy & Sustainability Statement, by Greengage; . Land Contamination Assessment, by Lustre; . Air Quality Assessment, by Gem Air; . Noise Impact Assessment, by Hann Tucker; . Waste Management Details, by Evoke; . Topographical Survey, by CBRE; and . Daylight/Sunlight Assessment by Delva Patman Redler.
Environmental Impact Assessment
1.6. A request for a Screening Opinion was submitted to the Local Planning Authority (LPA) on 6 October 2019 in accordance with Regulation 6 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017.
1.7. Oxford City Council issued a Screening Opinion on 3 November 2020 which states that the proposals are not considered to be EIA development. A copy of the LPA's screening opinion is attached at Appendix 1.
Planning Statement Structure
1.8. The remainder of this Statement is set out as follows:
. Section 2 describes the Site and its surroundings; . Section 3 provides the planning history of the Site; . Section 4 provides details of the proposed development; . Section 5 summarises our pre-application consultation and engagement; . Section 6 sets out the planning policy context for the Site and the proposed development; . Section 7 sets out the planning balance - assessing the proposal against the Development Plan, and having regard to other relevant material considerations; and . Section 8 concludes the case for granting planning permission.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
2. The Site and its surroundings
2.1. The Site is located on the south side of the A40, on the eastern outskirts of Oxford, directly adjacent to Risinghurst and south of Sandhills. The Site is located 5.5km from the city centre, and is well connected to Oxford city, including its train station, via the local bus services and cycle routes that run along the A40 and London Road. Thornhill Park & Ride also lies immediately to the east of the Site, and provides very regular bus services to London, and to Heathrow and Gatwick Airports.
2.2. The Site is also less than 2km from Headington High Street, which offers a wide variety of services including cafes, food stores, retail and community facilities. It is also very well situated for the John Radcliffe and Churchill Hospitals, Oxford Brookes University’s main campus, and the nearby Barton Leisure Centre.
2.3. The Site, formerly used by AC Nielsen for employment purposes, is primarily accessed via a main vehicular entrance directly from the A40. The site frontage, to the A40, is also bounded by mature trees and shrubs, and a low stone wall. There is also a pedestrian/cycle access leading to Grovelands Road, in Risinghurst.
2.4. The buildings to the east of the Site (the former AC Nielsen offices) have recently benefitted from prior approval for their conversion to residential use, along with detailed planning permission for external alterations to the buildings (see Section 3).
2.5. Historically there was a vehicular egress to the north western corner of the Site, linking with the A40, but this was required to be closed to vehicles as part of the conditions associated with the prior approval, and is now only intended for pedestrians, cycles and emergency use.
2.6. The Site itself currently comprises a large area of former office car parking (0.98ha of the wider Site), brick buildings that were ancillary to the employment site, including Forest Lodge and The Cottage, which had historic associations with Shotover Park, and a large open space to the south side of the former offices. The Site is bounded by mature trees and hedgerows. There are also groups of matures trees within the northern part of the Site, and a hedge and trees divide the car park from the open space. This open land was formerly used as a sports ground associated with the A C Nielsen site. Historically there were also tennis courts on the land.
2.7. The Site is currently only in informal use as a car parking facility and amenity grassland area associated with the recently converted apartments. The site comprises; 8,838 sqm of parking areas / roads / hard surface, 1,147 sqm of existing building footprint and 23,415 sqm of greenfield space.
2.8. Further to the south lies Risinghurst Cricket Club’s ground. To the south east there are arable fields, and further beyond that Forest Hill and Shotover Country Park, which is a Registered Park & Garden. There is also a long distance footpath along the eastern boundary.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
2.9. To the west is the residential neighbourhood of Risinghurst, and north of the A40 lie the neighbourhoods of Sandhills and Barton. There is a primary school, a specialist school and a leisure centre at Barton, all approximately 500m from the centre of the Site.
2.10. The Site itself is not subject to any specific environmental designations. It is located within the Environment Agency Flood Zone 1, and as such is at a low risk (less than 1 in a 1000 annual probability) of fluvial flooding.
2.11. The Site sits within the “Midland Ridge” National Character Area 109, which is predominantly characterised by bands of low-lying limestone hills stretching east–west, from the Vale of Aylesbury in Buckinghamshire to Swindon.
2.12. The Site is also located, at a county level, within the landscape character type of ‘LCT 19: Wooded Estatelands’ and subsequently at a city level ‘LCT 6C Enclosing Limestone Hills – East Oxford Heights’.
2.13. The quality of agricultural land on the eastern edge of Oxford is classified as Grade 3 - “good to moderate”.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
3. Planning history
3.1. The former Nielsen House was built in 1957 and was originally a single storey office building. Additional floors were added in the 1960s to create a three-storey office building arranged as a quadrangle with a landscaped courtyard. A group of smaller buildings adjoin the former Nielsen House; these comprise a three storey office building (which had a bridge link to Nielsen House at first and second floor level) and the former red brick lodge (‘Forest Lodge’) with its associated outbuildings, including ‘The Cottage’.
3.2. In December 2017, under application reference 17/02969/B56, the Applicant received the Council’s prior approval for the change of use of Nielsen House and the adjoining three storey office building to provide 114 x 1-bed flats and 20 x 2-bed flats, which sits on an area of 1.52 ha immediately to the east of the Site.
3.3. A previous submission for 30 x 1-bed and 63 x 2-bed flats was also approved in 2016, under application reference 16/02678/B56.
3.4. Separate detailed planning permission for the replacement of windows and doors and installation of cladding and rendering, the erection of a cycle store and alterations to landscaping and car parking was granted in December 2018, under application reference 18/02737/FUL.
3.5. Subsequent applications for the discharge of conditions associated with the above permissions, relating to external materials and openings, landscaping, cycle parking, footpath improvements, travel plan and access to and from the A40, were approved in 2018, 2019 and 2020.
3.6. Work has now been completed on this conversion, including the provision of new landscaping, boundaries and parking courtyards, and the buildings are now fully occupied. The two main former office buildings are now known as Thornhill Court and Marley House. As mentioned in Section 2, new occupiers are making some informal use of the Site as a car parking facility and amenity grassland area associated with the recently converted apartments.
3.7. The Applicant now wishes to progress the development of the remainder of the allocated site, in line with the principles of the recently adopted Local Plan and Policy SP47. This application has been progressed over the last three years, from an original scheme concept in early 2018, through pre-application discussions with the LPA and key stakeholders, and more detailed consultation and engagement during 2019, 2020 and the early part of this year.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
4. The proposed development
4.1. The description of proposed development is as follows:
“Development of 402 apartments (Class C3), a 133 bed hotel (Class C1), employment provision in the form of an Innovation Centre, with additional mixed use accommodation to include office space, gym, café and restaurant (all within Class E), public open space, associated landscape and the provision of a new vehicular access onto the A40.”
4.2. The scheme will comprise:
. 402 apartments, ranging from 1 to 4 bed units; . 95 residential car parking spaces and secure cycle parking spaces for residents; . A hotel with 133 rooms and car parking provision (26 spaces); . An “Innovation Centre”, providing circa 2,200 square metres of commercial floorspace; . Mixed use floor space, of circa 2,000 square metres, including office, gym, café and restaurant; . Public open space, with community gardens, play areas and associated landscape; and . The formation of a new vehicular access onto the A40.
4.3. Given the existing conversion of the former offices to residential use, providing 134 units, the addition of 402 apartments within the Site will deliver a total of 536 new dwellings across the whole area that is allocated under Policy SP47, and which is in line with the policy requirement.
4.4. In accordance with Policy H2, 50% affordable housing will also be included within the scheme. A statement on Affordable Housing provision is contained within Section 6 of this document.
4.5. A range of measures will be provided at Thornhill Park to support and, where necessary, mitigate the impacts of development including, but not limited to:
. A high quality, safe, accessible and walkable neighbourhood, with improved connectivity; . The promotion of active travel and easy access to sustainable modes of transport; . The creation of new community facilities, including communal gardens and public open space; . On site employment, services and facilities, helping to reduce the need to travel and improving health and well-being; . Sustainable drainage, use of energy efficient measures and renewable resources; . Ecology enhancements and biodiversity net gain; . Landscape enhancement and management; . Construction & Waste Management Plans.
Residential amenity
4.6. All apartments are compliant with the Nationally Described Space Standards (NDSS) and Oxford City
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Council planning policy. Details of those the apartments comply can be found within the Policy Compliance chapter of the DAS.
4.7. The apartments, arranged in buildings ranging between 3 and 6 storeys in height, have been designed to minimise overlooking to both neighbouring properties and new buildings, with suitable separate distances. In locations where the separation distance is below 18m the primary windows have been positioned so there is no direct overlooking or the buildings have been orientated so the windows are orientated away from each other. The higher buildings are generally set within the centre of the site, with the lower 3 storey buildings located to the western side, adjoining existing housing in Risinghurst.
Access, parking and connectivity
4.8. Following pre-application discussions with Oxford City Council, it was agreed that the Site’s new main vehicular access should be relocated to a gap in the existing trees along the A40 site frontage, west of the existing vehicular access. Vehicular access into and out of the Site will be primarily via this new vehicular access, and there will also be internal connection with the existing Thornhill Court scheme.
4.9. The existing main vehicular access will be closed to traffic, but retained for cycle and pedestrian use. The new vehicular access will, therefore, service both the Site and the existing Thornhill Court / Marley House scheme. It is not intended that the proposals will incorporate any off site alterations to the main A40 carriageway, but the new access will enjoy an improved form compared to the existing.
4.10. The application is supported by a full Transport Assessment and two Travel Plans (one for the residential and one for the hotel), and the key components of these, and their relation to policy and material considerations are discussed in Section 7.
4.11. The general approach to the development is to reduce reliance on private cars and to encourage active travel and the use of public transport.
4.12. The level of car parking proposed is based on Policy M3 of Oxford City Council’s adopted Local Plan, which allows only a maximum of one space per residential unit. In line with the aspirations of the Policy and the advice of City Council planning officers to reduce parking provision, the development proposes a total of 95 unallocated residential parking spaces, including 20 disabled persons parking spaces.
4.13. The limited car parking being made available compliments the sustainable location and the incorporation of employment space and mixed uses at the Site, in line with the policy aims for the site. The level of parking provision proposed, combined with the ready availability of sustainable travel modes and the provision of employment at the Site, will help to suppress car ownership and therefore the level of car born trip generation originating from the development.
4.14. For the hotel 26 parking spaces including two disabled persons parking space are being provided, again reflecting the sustainable location of the site. The proposed innovation centre is car-free.
4.15. Car club spaces are also being proposed, which will provide residents with an alternative to owning a car
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Planning Statement Thornhill Park, London Road, Headington, Oxford
and further reduce traffic levels and the need for on-plot parking spaces, as will the provision of walking and cycling connections to existing routes through adjacent urban areas and on into Oxford city.
4.16. At the same time cycle parking spaces are proposed for residents, in secure locations, with additional ‘short stay’ Sheffield stand cycle parking spaces in the public realm areas. The hotel will benefit from secure cycle parking spaces, and an additional secure cycle parking spaces are proposed for the Innovation Centre.
4.17. Although Thornhill Court and Marley House sit outside of the Site which is the subject of this application, they are located adjacent to it, within the wider masterplan for the allocated land and the Applicant’s ownership, and are now in residential occupation. The wider site has therefore also been considered, in particular in relation to the parking provision around Marley House, including car club spaces, and the DAS and supplementary masterplan explains how this could be arranged to improve the scheme’s setting in the future, in particular in the context of the proposed Village Green.
4.18. Consideration is also given in the DAS as to how residential parking areas may be reduced and phased out over time, to be replaced by landscape and other amenity areas.
The Site has also been designed to allow for Oxford City Council’s refuse vehicles to access and egress the site in a safe and efficient manner, although ultimately it is likely that a private contractor would service the site
Landscape and green infrastructure
4.19. The overarching place making vision for Thornhill Park is a ‘landscape led’ approach, utilising existing green infrastructure to craft a new and special place with a distinctive character and a strong community focus. The design approach has been one which seeks to draw the best from the existing site features, including the mature trees, and from the wider landscape character and local context. It responds to the issues of ecology, access, landscape, townscape and surface water management in an integrated way, to create a multi-functional landscape.
4.20. The proposed landscape framework plays a key role in tying the development together as a comprehensive and pleasant new environment in which to live and work. The inherited landscape, including the retention of many of the mature trees, will provide a high quality and established setting for open spaces and new homes, creating the opportunity for the landscape to define, shape and inform the character of the spaces and the architectural response.
4.21. It is also important to enhance the place by connecting the existing fractured mosaic of spaces and creating a new green infrastructure layout that plugs into the wider network. The new design therefore introduces a clear hierarchy of green spaces and linkages that form a connected multi-functional landscape framework for the proposed development and the surrounding neighbourhoods. The design ethos and the evolution of the landscape strategy is explained in more detail in the DAS.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Sustainable drainage
4.22. The application is accompanied by a Flood Risk Assessment and a Drainage Strategy. The Drainage Strategy outlines the Sustainable Drainage Systems (SuDS) that have been chosen for the site based on their suitability, coordination with the landscape proposals and retained tree plans, the proposed ground levels and proximity to existing buildings.
4.23. The proposed surface water drainage solution maximises SuDS opportunities across the development to provide suitable attenuation and produce no flood risk for or from the site.
Biodiversity
4.24. Preliminary ecology appraisal work shows that the site has potential to support protected and notable species, and further detailed survey work is being proposed to support the preparation of an Environmental Management Plan and Biodiversity Enhancements.
4.25. Overall it is intended that the development will deliver net biodiversity gain.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
5. Statement of Community Involvement
5.1. The initial design concept was prepared in early 2018, and the Applicant has progressed carefully through a substantial programme of consultation and engagement since then.
5.2. In summary the proposals have been subject to:
. Four Pre-application meetings with Oxford City Council (OCC) between November 2019 and December 2020; . A pre-application workshop with OCC, and key consultees, including Highways Officers at Oxfordshire County Council; . Oxford Design Review Panel (ODRP) Workshops, held in July and December 2020; . Public consultation, in November 2020, based on the pre-application materials and hosted via the Thornhill Park website; . A presentation was made to the Risinghurst and Sandhills Parish Council on the 15th October, which included a Q&A session; . Specific conversations with OCC about the Innovation Centre employment provisions, in November 2020; . A meeting with the Oxford Civic Society, on the 19th January 2021; . A public meeting with local residents and local Councillors, on the 20th January 2021; . A workshop with Oxford City Council officers on 4 March 2021; and . A Risinghurst and Sandhills Parish Council update given on 7th June 2021.
5.3. Details of this engagement, and how it has informed the evolution of the proposals, are also provided within the Design and Access Statement.
5.4. An initial pre-application discussion occurred with the City Council in March 2018 and the following items were considered to be key issues for the development:
The form and height of buildings on the frontage facing the A40 need to be properly considered as they could help reinforce this gateway to the city.
The density of development needs to be considered in more detail in order to ensure that the site makes the most efficient use of land. The location could allow for higher densities and this should be explored, bearing in mind views out from the city.
The site has a number of important assets – mature trees, frontage onto the protected open space to the south, and park and ride and countryside to the east, pedestrian/cycle links to the surrounding residential area. These should be identified on a site analysis plan.
Any development needs to make best use of the connections to the surrounding residential to ensure that it is feels part of Risinghurst and that it facilitates movement throughout the area.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Fronts and backs, defensible space, space around buildings, areas of shared open space all need careful consideration.
5.5. The DAS sets out how, following the on-going input from the City and County Councils, the options for the site have involved the ODRP and statutory consultees. The most recent ODRP feedback, in December 2020, commented that there has been a great deal of progress from the previous workshop, and that the scheme was moving in the right direction with a better balance in height and density on the site, and the site layout and landscape proposals have developed. However, there were still some areas where some further improvement and design work were needed.
5.6. The proposals as submitted have sought to respond to the feedback received during the pre-application process and following the ODRP sessions.
5.7. Feedback from the Risinghurst and Sandhills Parish Council comprised the following points;
Comments
1. There is support for a new vehicle access from the A40. 2. There is support for a cycle/ pedestrian access to Grovelands Road. 3. There is support for a cycle /pedestrian access from Downside End to Thornhill Park & Ride. 4. The principle of being environmentally-led and creating green spaces is very welcome. 5. There is positive comment on the design and layout of the site.
Concerns
1. The accommodation could be cramped and therefore create a poor-quality living experience. 2. Residents have concerns over the vehicle access to the development. It is very limited with only one access onto the whole site. A second access with a one-way system would help traffic flow. 3. There is limited parking provisions on the proposed development which could lead to on-street parking on Risinghurst, which is a big concern. 4. Will parking for the hotel will be at Thornhill Park & Ride? 5. Is there a proposed “green” access route for pedestrians/cyclists to the Park & Ride across the Footpath as the schematic indicates? 6. The height of the proposed buildings behind Pond Close is a concern because Pond Close is low- lying and this could cause light problems. 7. The height of the buildings between the Hotel and the Terrace houses backing on to Downside End, could also cause light problems. 8. Access for emergency vehicles, delivery vehicles and contractors etc. There is a lack of provision for turning and parking, which could well cause verges to be damaged. This can be seen on the Risinghurst estate with the damaged grass verges which is a big problem. 9. Who will have the responsibility of the upkeep and maintenance of the green space proposed?
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Planning Statement Thornhill Park, London Road, Headington, Oxford
5.8. Public consultation has also been held on the proposals, which took place during November 2020. Due to Covid-19 lockdown restrictions, online public consultation was carried out, and a webpage was created with details of the proposals and an online feedback form.
5.9. Feedback received from the wider public on the proposals, and in relation to the meetings held in January and March 2021, along with the Applicant’s responses, are summarised under a series of key headings as follows;
Parking
5.10. Concern was raised both about not enough parking being provided, and also about too much parking being provided. The Local Plan policy allows for higher parking ratios, but planning officers have encouraged a lower standard of parking at this Site, to generally discourage private car use and ownership. The proposed parking provision, with 95 spaces for the housing and 26 spaces for the hotel, represents a compromise between those two positions.
5.11. Concern was also raised about the potential for off-site parking resulting in Risinghurst, if some Thornhill Park residents are unable to park on-site. The County Council is proposing a future Controlled Parking Zone for Risinghurst, which will provide parking suitable controls to prevent unauthorised parking.
Carbon Footprint
5.12. Comments received encourage greater energy efficiency. The proposals will aim for a 40% saving in energy in comparison with 2013 Building Regulations, as required by the Local Plan. This will include use of solar panels and ground source heat pumps.
Sunlight / Daylight
5.13. Concern was raised about the potential impact of the proposals on existing housing in Risinghurst. The Local Plan sets out criteria by which to judge privacy, daylight and sunlight with 25 degree and 45 guidelines. The proposals are consistent with those guidelines.
Hotel opening times
5.14. Comments included concerns about the potential late opening of the hotel bar and restaurant, with associated concerns about possible late night anti-social behavior. The issue can be addressed with the use of planning conditions following consultation with the City Council Environmental Health officer.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Air Quality
5.15. Some local residents raised the issue of air quality as a concern. The application includes an Air Quality Assessment. The lower standard of car parking, and encouragement of cycling and public transport, together with provision of a safe pedestrian crossing of the A40 to encourage walking to school, should contribute to the mitigation of the effect of the development proposals on air quality in the local area.
Setting a precedent for development on the adjoining cricket pitch
5.16. Concern was expressed that development at Thornhill Park would set a precedent for the cricket pitch to the south of the site. No precedent is being set as the Site is allocated for residential development and the existing cricket pitch enjoys protection by Local Plan policies and NPPF guidance on the development of playing pitches. The proposals at Thornhill Park are expected to provide a financial Section 106 contribution to improve facilities at Risinghurst Cricket Ground.
Vehicular access
5.17. Some local residents expressed concern about the potential for vehicles to drive from the Thornhill Park site to the adjoining housing in Risinghurst via Downside Road. The proposals only provide for pedestrian and cycle access via the access on the western edge of the Thornhill Park site. The only vehicular access and egress would be to and from the A40.
Traffic
5.18. The issue of traffic on the A40 was raised by some local residents. The transport implications of the proposals will be set out in a Transport Assessment, which forms part of the planning application. This assessment will consider the impact of additional traffic on existing junctions, and it finds that there is a limited impact due to the modest levels of parking.
Safe routes to school
5.19. Some residents referred to the need for safe routes to school. The County Council has requested a financial contribution to help fund a new controlled crossing on the A40 which is envisioned to be part of the CIL payment.
Scale of development
5.20. The overall scale of development was a concern for a number of residents. The density of the development including the height of the proposed buildings is based on the adopted Local Plan policy for the Site, which requires a minimum of 400 dwellings, of which 50% need to be affordable. The density and layout required to accommodate a minimum of 400 dwellings means a development of flats is required at the heights proposed.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Flooding
5.21. Concern about flooding was raised by a number of local residents. The planning application includes a Flood Risk Assessment to demonstrate no increase in flood risk, and these issues are also considered in Section 7. The drainage proposals are based on sustainable drainage principles, such as swales.
Ecology
5.22. Some residents expressed concern about the loss of wildlife habitat on the site. The proposals will demonstrate a net benefit in biodiversity as a result of the ecological proposals, and the application is accompanied by ecology assessments to demonstrate this.
Fencing on the eastern boundary
5.23. There was concern raised about the type of fence on the eastern boundary of the site. The boundary treatment of the site on the eastern edge adjoining the footpath remains to be agreed, and it is proposed to be the subject of a pre-occupation condition.
Trees
5.24. A number of local residents raised concern about the potential loss of trees. The site is the subject of a group Tree Preservation Order and trees will be retained where possible, subject to meeting the policy requirements set out in the adopted Local Plan such as the minimum number of dwellings and the potential for complementary uses, such as the hotel and the employment building known as the ‘Innovation Centre’. All plans have been developed in conjunction with City Council officers.
School Capacity
5.25. Some local residents queried whether local schools had capacity to accommodate the additional children from the development. The County Council, as Education Authority, will be consulted on the planning application. The County Council will advise whether existing schools have capacity for the estimated number of children, or whether there will be a requirement to extend existing schools to increase capacity. The Community Infrastructure Levy could provide funding to support additional capacity and learning requirements.
What type of employment?
5.26. There were queries about the type of employment to be provided. The Innovation Centre is proposed to have a mix of employment uses with 50% of the office floorspace for ‘co-working’ and 50% for conventional office use. The building is also proposed to include meeting space for both business and community use. The hotel will also provide a range of jobs.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Local shops
5.27. Some local residents queried whether the proposals would include a local shop. The proposals do not include a local shop, following concerns raised by City Council officers that such a facility was unlikely to be viable in this location.
Affordable housing
5.28. The issue of rent levels for the affordable housing was raised by some local residents. The proposals provide for 50% affordable housing consistent with the policies of the adopted Local Plan, including the tenure split - namely 80% social rent and 20% intermediate housing. The rent levels will be set by the registered providers, in line with the City Council’s affordable housing policy.
Light pollution
5.29. Some local residents queried how light pollution would be minimised. The proposal will provide for directional lighting in order to minimise light pollution. The issue of lighting is expected to be the subject of an appropriate pre-occupation planning condition.
Electric charging points
5.30. The level of electric charging points was raised by a number of local residents. The proposals provide for a number of electric charging points, consistent with the requirements of the adopted Local Plan, namely one for each allocated parking space and 0.25 provision.
Why a hotel?
5.31. Some local residents queried why a hotel is being proposed. The adopted Local Plan policy provides for complementary uses to be provided in addition to residential development. Work undertaken by the applicants indicates that there is significant commercial demand for additional hotel development in Oxford in general and on this site in particular, and the Council’s own short stay accommodation policy supports additional accommodation in the City, including along the key radial routes and close to main public transport hubs. Additional overnight accommodation increases local spend and the ‘dwell time’ visitors spend in the City, allowing for benefits to the local economy. Provision of a hotel would provide uses such as café/bar, restaurant and a gym, which could also serve local residents from Thornhill Park and the surrounding area.
Timescale for development
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Planning Statement Thornhill Park, London Road, Headington, Oxford
5.32. Some local residents queried the likely timescale for the development. The planning application is likely to be submitted in early 2021. The timescale of the granting of planning permission is a matter mainly for the City Council as the local planning authority. It is assumed that detailed planning permission would be granted, following completion of a Section 106 planning obligation, in 2022. On the assumption that development commences in 2022, the first residential occupation could be in 2023 with a development timescale of at least two to threeyears, to perhaps 2025.
Allotments
5.33. A number of local residents queried whether allotments would form part of the proposals. The planning application will include allotments on the eastern part of the site.
Cycling
5.34. The issue of cycle storage was raised by some local residents. The planning application will provide cycle storage to meet City Council standards within and adjoining the proposed residential blocks, for example ensuring adequate headroom and spacing with acceptable bicycle rack designs.
5.35. The provision for cyclists seeks to reflect guidance in LTN 1/20, for example proposing that external bicycle racks are sheltered, well-lit and overlooked for security.
Gym
5.36. The issue of the proposed gym was raised by some local residents and queried whether it would be open to local residents. The proposed gym would form part of the proposed hotel and the issue of gym membership would be a matter for the hotel operator. It is noted that many hotels with gyms do offer membership to local residents.
Access to Thornhill Park & Ride
5.37. A number of local residents raised the issue of access from the Thornhill Park site to the Thornhill Park & Ride site. The existing access to the Thornhill Park & Ride site on the A40 provides a convenient access for residents at Thornhill Park. The proposals also provide the potential for a pedestrian access on the eastern edge of the Thornhill Park site.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
6. The Development Plan
6.1. Section 38(6) of the Planning and Compulsory Purchase Act 2004 directs Local Planning Authorities to determine planning applications in accordance with the policies of the Development Plan unless material considerations indicate otherwise. Section 38(3) of the Act provides that the Development Plan includes the “development plan documents (taken as a whole) which have been adopted or approved in relation to that area”. The adopted statutory Development Plan for Oxford City Council comprises the following relevant document:
. The Oxford Local Plan 2016-2036 (adopted June 2020);
6.2. Material considerations also include national policy, which is primarily expressed through the National Planning Policy Framework (NPPF) and National Planning Practice Guidance, as well as additional guidance produced by the Council in the form of Supplementary Planning Documents (SPDs) and Technical Advice Notes (TAN). The Government is currently consulting on proposed amendments to the NPPF, and a new draft National Model Design Code, until the 27th March 2021. The effects of this consultation upon the national guidance are, as yet, unknown and may not impact upon the determination period for this application.
The adopted Development Plan
6.3. The Oxford Local Plan was adopted in June 2020 to guide development across the City until 2036. It sets out the overarching spatial strategy and housing requirements for the City until 2036. The adoption of this new plan has allowed the Council to supersede many outdated Development Plan Documents.
6.4. The table over the page summarises the national guidance, local planning policies and supporting documents that inform the consideration of this application:
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Planning Statement Thornhill Park, London Road, Headington, Oxford
NPPF Local Plan 2036 Other planning
(Paragraphs) documents
Principle of SP47 (Thornhill Park) Residential Led 7-14 RE2 (Efficient use of land) Mixed-Use 117-121 G5 (Outdoor sports) Development H1 (The scale of new housing provision) H4 (Mix of dwelling sizes) 59-61 H7 (Community led housing and self-build) Technical Advice Note: Housing 67-72 H10 (Accessible and adaptable homes) Space Standards for 122-123 H14 (Privacy, daylight and sunlight) Residential Development H15 (Internal space standards) H16 (Outdoor amenity space) Affordable H2 (Delivering affordable homes) 62-64 Housing Employment 80-82 E1 (Employment sites) DH1 (High quality design and placemaking) Technical Advice Notes: 122-123 Design DH2 (Views and building heights) High Buildings & External 124-132 DH7 (External Servicing) Wall Insulation 193-196 DH3 (Designated heritage assets) Heritage 199-200 DH4 (Archaeological Remains) 197 DH5 (Local Heritage Assets) G1 (Protection of green and blue infrastructure network) G2 (Biodiversity) 96-98 Natural G5 (Outdoor sports) Technical Advice Note: 170-177 Environment G7 (Protection of existing green infrastructure Biodiversity
features) G8 (New and enhanced green infrastructure) G9 (Green and blue infrastructure)
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Planning Statement Thornhill Park, London Road, Headington, Oxford
RE1 (Sustainable design and construction) RE2 (Efficient use of land) RE3 (Flood risk management) RE4 (Drainage) RE5 (Health, wellbeing and Health Impact Technical Advice Notes: 112 Assessments) Energy Statement, Air Environmental 148-165 RE6 (Air quality) Quality & Waste Storage 178-183 RE7 (Managing impact of development) RE8 (Noise and vibration) RE9 (Land quality) V8 (Utilities – water and sewage) V9 (Utilities – broadband) Social and 80-82 V5 (Sustainable tourism)
Community 91-92 V6 (Cultural and social activities) M1 (Prioritising walking, cycling and public transport) M2 (Assessing and managing development) Transport 102, 110 M3 (Parking) M4 (Electric charging points) M5 (Cycle parking)
Other material considerations
Planning Practice Guidance
6.5. The Government published the Planning Practice Guidance (PPG) in 2014 and has since updated relevant parts, as appropriate. The PPG provides further detailed guidance accompanying the Framework. The following sections of the PPG have been considered in the preparation of this planning application:
. Air Quality; . Climate change; . Design; . Effective use of land; . Flood risk; . Healthy and safe communities; . Housing; . Natural environment; . Noise; . Open space, sports and recreation facilities, public rights of way and local green space; . Renewable and low carbon energy; . Travel Plans, Transport Assessments and Statements; . Waste; and . Water supply and wastewater.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
The City Council’s Community Infrastructure Levy (CIL)
6.6. Oxford City Council’s CIL Charging Schedule was implemented in October 2013 and is charged on new developments within the planning authority area, in order to fund necessary infrastructure requirements, alongside contributions collected via S106 agreements, as may be appropriate.
6.7. The changes to the Use Classes Order, which came into force in September 2020, includes the re-grouping of Class B1, A1, A2 and A3 uses, and certain former Class D1 and D2 uses, such as gymnasia, surgeries and nurseries, under the new Use Class E. This change is not currently reflected in the published CIL charging schedule.
6.8. The latest Charging Schedule (January 2021) applies a CIL rate of £148.64 / sq m for Class C3 residential and former Class A uses, including café/restaurant. The Schedule also sets a CIL rate of £29.72 / sq m for Class C1 hotels, and the former Class D1, Class D2 and Class B1 uses.
6.9. The planning application is accompanied by the relevant CIL forms.
Affordable Housing Statement
6.10. Policy H2 of the Local Plan states, inter alia, that;
Planning permission will only be granted for residential development if affordable homes are provided in accordance with the following criteria:
a) On self-contained residential developments (C2 and C3, including retirement homes, sheltered housing, but excluding student accommodation and employer-linked housing) where sites* have a capacity for 10 or more homes (gross) or exceed 0.5 ha, a minimum of 50% of units on a site should be provided as homes that are truly affordable in the context of the Oxford housing market (defined in the Glossary).
At least 40% of the overall number of units on a site should be provided as on-site social rented dwellings. The remaining element of the affordable housing may be provided as intermediate forms of housing provided that they are affordable in the Oxford market. The affordable homes must be provided as part of the same development (‘on-site’) to ensure a balanced community. Where affordable housing is provided onsite it should incorporate a mix of unit sizes (see Policy H4 on housing mix).
* site area includes everything within the red line boundary of the planning application, which may include existing properties which are being materially altered.
6.11. Policy H4 on Housing Mix states, inter alia, that;
Planning permission will be granted for residential development that is demonstrated to deliver a balanced mix of dwelling sizes to meet a range housing needs and create mixed and balanced communities.
Proposals for 25 or more homes (gross) (C3 residential), or sites of 0.5 ha. and greater, and which are
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Planning Statement Thornhill Park, London Road, Headington, Oxford
outside of the city centre or district centres, will be expected to comply with the following mix of unit sizes for the affordable element, where it is feasible (this does not apply to employer-linked affordable housing):
1 bedroom homes ...... 20-30%
2 bedroom homes ...... 30-40%
3 bedroom homes ...... 20-40%
4+ bedroom homes ...... 8-15%
6.12. The Council’s Affordable Housing and Planning Obligations SPD (adopted in September 2013) sets out guidance on matters relating to affordable housing, planning obligations and the Community Infrastructure Levy (CIL).
6.13. A total of 402 new homes are proposed at the Site, and of these 201 will be affordable, in accordance with the definition set out in the NPPF Annex 2, and representing 50% of the total being developed. The dwellings will also be designed to accord with Nationally Described Space Standards.
6.14. It is the Applicant’s intention to provide the dwelling size mix and tenure split in line with Policies H2 and H4 as set out above, and to enter into the necessary S106 Obligation to secure their delivery, in line with the SPD guidance.
Self-Build
6.15. Policy H7 of the Local Plan states that;
“Proposals for self-build housing will be supported as a way of enabling people to meet their own housing needs, particularly community-led collective self-build. On residential sites of 50 units or more, 5% of the site area developed for residential should be made available as self-build plots. Employer linked affordable housing, student accommodation, C2 accommodation and residential development in conversions or on brownfield sites where only flatted development is provided are excluded from this requirement.”
6.16. The Site is partly previously developed land, and the proposed residential component of the scheme is entirely flatted. As such, it is not proposed that the development will include self-build housing plots.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7. Planning assessment
7.1. This section of the Planning Statement provides an assessment of the proposed development against the development plan, NPPF, and any relevant material considerations including planning history for the application site. This section of the Statement seeks to address key planning issues arising from the proposal. Such issues have been identified through both pre-application discussions with City Council Officers and through review of the planning policy framework that applies to the site.
7.2. Section 38 (6) of the Planning and Compulsory Purchase Act (2004) states that if regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise.
7.3. This section addresses the planning matters that are relevant to the application. These include whether or not the:
. principle is acceptable; . design is appropriate; . proposals will preserve and enhance heritage assets; . proposals raise any highway issues; . proposals are technically acceptable, including in relation to:
o Energy and Sustainability o Drainage o Ecology o Trees o Air Quality o Noise o Contamination o Waste Management
7.4. Each of these matters will be considered below.
Principle of the development
7.5. The specific wording of Policy SP47, in the adopted Local Plan, is as follows;
“Planning permission will be granted for a residential-led mixed use redevelopment of the Thornhill Park site. This should include some employment use, given the strategic location of the site. Other complementary uses will be considered on their merits.
The minimum number of homes to be delivered is 534, which includes the conversion of the existing building to residential.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Opportunities should be taken to improve connectivity to and within the site for pedestrians and cyclists.
The playing field must be retained unless its loss can be otherwise compensated for in line with the requirements of Policy G5. If an alternative site is found the City Council must be satisfied that it will be delivered."
7.6. In relation to employment provision required by the policy, the applicant is proposing an Innovation Centre using the existing lodge and a proposed four storey extension. The proposed employment floorspace is 2,325 sq m as a gross internal area. On the assumption that the gross internal area is 15% more than the net internal area, the net internal area would be 1,976 sq m. This excludes the roof space in Forest Lodge, which has not been measured.
7.7. On the basis of assumed employment densities for general offices (formerly Class B1a uses and now Class E) we have assumed full time employee per twelve square metres (net internal area). This would equate to at least 165 full time employees, and assuming that the lodge roof space is not also utilised for office use.
7.8. Additional employment will also be generated at the site through the operation of the hotel, café / restaurant and ancillary office hub.
7.9. In relation to the loss of the former playing field, which is proposed for development, the Applicant is proposing to make a financial contribution, tied to a S106 Agreement to ensure its delivery, for the upgrade to facilities at Risinghurst Cricket Ground on the adjoining site to the south. This is proposed as direct compensation for the loss of the playing field, aligned with Policy G5 (b), and bearing in mind the overall benefits of the scheme in the planning balance.
7.10. In addition, the proposal makes effective use of a previously developed / ‘brownfield’ site as encouraged by paragraphs 117 and 118 of the NPPF, and in line with Policy RE2 of the adopted Local Plan, which seek to maximise the use of previously-developed sites and support the development of under-utilised land and buildings, and in line with Policy E1, in as much as the site was formerly used in association with employment at Nielsen House.
7.11. Given the above, the proposals accord with Policies SP47, RE2, E1 and G5 of the adopted Local Plan, and paragraphs 117-118 of the NPPF. The principle of development is therefore considered to be acceptable.
Design
7.12. Policy DH1 (High quality design and placemaking) states that planning permission will only be granted for development of high quality design that creates or enhances local distinctiveness. As required by Policy DH1, a Design and Access Statement (DAS) accompanies this planning application. This document, prepared by JTP, seeks to meet all of the key design objectives and principles set out in Appendix 6.1 of the Local Plan.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Responding to site character and context
7.13. The first section of the design checklist in the Local Plan Appendix relates to responding to site character and context. The DAS provides a detailed analysis of the site and its context which has informed the design of the proposed buildings. This includes an analysis of the site constraints, historic context, urban structure and grain, local materiality and appearance, connections, nearby heritage assets, views and landscape character. The opportunities and constraints of the site are then presented and the evolving design rationale for the proposals is discussed through Section 2 of the DAS.
Natural Features and Resources
7.14. In terms of natural features and resources, sunlight and daylight studies have been undertaken which have informed the layout and location of buildings and amenities.
7.15. The proposals have incorporated biodiversity enhancements as discuss further below. Sustainable drainage systems have also been incorporated into the proposals as outlined in the drainage section below.
Movement
7.16. The DAS includes movement plans to show how pedestrians, cyclists and vehicles would access the Site, and the various spaces and buildings, from different directions.
7.17. The movement strategy is based on the key principle of creating prioritised and legible routes for pedestrians and cyclists. The necessary vehicular access routes are designed to be part of the landscape, but not dominant over it. Strong north - south connections for pedestrians are provided and cyclists have the option of two entry points from the A40 London Road. Where there are vehicular routes, these will have associated pavements for pedestrians.
Designing development blocks, density and uses
7.18. The DAS provides information of how the proposed buildings will be used, the disposition of uses and the overall density of different parts of the site, bearing in mind the character areas and landscape structure that are being proposed.
7.19. In particular, the DAS explores the massing development of the proposed buildings in further detail, and provides explanation of the scale and massing of the proposed buildings, bearing in mind the context of existing buildings, landscape features and wider impacts on landscape and visual amenities.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.20. The proposed buildings have sought to maximise development on the site whilst enhancing its appearance to provide a high quality development appropriate for its surroundings in accordance with Policy RE2, which states that planning permission will only be granted where development proposals make efficient use of land. This policy goes on to say that development proposals must make best use of site capacity, in a manner compatible with the site itself, the surrounding area and broader considerations of the needs of Oxford. The specific issue of building heights and the design response to wider townscape and landscape considerations is explored further below.
Design of external areas
7.21. The DAS includes a landscape section which provides details of the public, semi-public and private external areas. This includes the streetscape, external landscaping and the design of areas, including lighting and boundary treatments, and measure intended to provide natural surveillance.
7.22. The DAS, and the evolution of the scheme that it describes, identifies how the proposals will create safe, accessible, inclusive and high quality external spaces.
7.23. The proposals incorporate the creation of a new green infrastructure network ties into the existing mature landscape, with a relevant palette of trees, and the retention of substantial areas of existing planting.
7.24. Car parking on the site has been limited, and the ability to easily move around the site on foot, and by cycle, are actively promoted. There are a number of opportunities to increase the accessibility and permeability of the site by upgrading the existing routes and opening up a new pedestrian access route through the site. Segregated pedestrian footpaths are provided across the proposed development, to provide pleasant, traffic free routes working their way north to the existing A40 walking and cycling network. Changes in surfacing provide indicative crossing points along key desire lines throughout the site. A footpath link is also proposed to the west into the adjacent residential area of Risinghurst, whilst a link to the footpath to the south is also maintained.
7.25. The DAS also provides details of how crime prevention, and Secured by Design principles, have informed the scheme design, including the layout of buildings, roads and footpaths, the surveillance of public space, and the detailed design strategies for lighting and boundary treatments.
Plots and Buildings
7.26. The proposed buildings seek to respect and enhance the character of the surrounding area and have been informed by character studies, as set out within the DAS. The needs of all users have been considered to ensure the design promotes access and inclusivity for all users.
7.27. The scale of the new buildings has also been carefully considered to ensure they are appropriate in the wider context. A Landscape and Visual Impact Assessment accompanies this submission demonstrating how the proposed buildings sit within close and distant views.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Daylight and Sunlight
7.28. A report by Delva Patman Redler has assessed the potential effects of the proposed development on daylight and sunlight to surrounding residential properties, including main back gardens and amenity spaces, using the methodology recommended in the Building Research Establishment (BRE) guidelines.
7.29. The assessment has been run against the existing baseline and the proposed development conditions and the potential effects of the proposed development have been quantified accordingly. The report also assessed the shadowing impacts on the amenity areas within the red line of the proposed development against the guidelines.
7.30. In daylight terms, overall the proposed scheme would have a largely negligible effect, with only some isolated areas of minor adverse impact on daylight to the neighbouring residential properties, and over 95% of neighbouring building facades meeting the BRE criteria or experiencing only minor adverse impacts. The average retained Vertical Sky Component (VSC) figure of 34.49% of visible sky remains excellent for a suburban location such as this, and well in excess of the 27% target criteria set by the BRE.
7.31. In sunlight terms, overall the proposed scheme would have a negligible impact on daylight to the neighbouring residential properties, with over 99% of neighbouring building facades achieving retained values in excess of 35% Annual Probable Sunlight Hours (APSH) and with only 1.93% of facades experiencing minor adverse impacts.
7.32. The report comments that the average retained Probable Sunlight Hours (PSH) figure of 81.1% of sunlight hours throughout the year remains excellent for a suburban location such as this, and well in excess of the 25% target criteria set by the BRE.
7.33. In shadowing terms, some additional shadowing will be cast on neighbour gardens in the early morning, but only up to around 10am, after which there will be no shadowing cast at all on neighbouring residential amenity areas.
7.34. Within the site itself 86% of the ground areas within the red line boundary for the site will achieve a minimum of 2 hours sun on ground on March 21, which is well in excess of the target criteria of 50%. The areas that will not achieve 2 hours are generally isolated to zones immediately to the north of the various building blocks.
7.35. Overall the report indicates that the primary landscape design is well designed around this and avoids primary amenity and sitting our areas in these less will sunlit areas of the site. This is a point also examined in some detail in the DAS.
7.36. In conclusion, it is submitted that the layout of the proposed development is consistent with the Council’s local planning policy on daylight and sunlight.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Loss of the existing sports field
7.37. As discussed under the principle of the development, whist the proposed development will involve the loss of the former playing field area, the Applicant is proposing compensation in the form of a S106 Agreement to make improvements to facilities at Risinghurst Cricket Ground on land to the south of the Site.
7.38. This facility will be of more direct benefit to the local community, and the proposal would accord with Policy G5 (b).
Healthy Placemaking
7.39. The DAS sets out in detail how the scheme is designed to ensure that it offers a healthy place to live, work and visit, and where the components of the design are capable of engendering well-being, positive community spirit and stewardship.
7.40. The narrative considers how the design of the urban fabric, the creation of a walkable neighbourhood, the integration of the natural environment, and the engendering of a strong sense of community at Thornhill Park, will all support this important design ethos.
Ensuring Quality
7.41. Overall, the design of the new scheme is considered to be of high quality and provides a positive contribution to the immediate surroundings and the wider Oxford landscape. The DAS demonstrates how the proposals meet the design objectives and principles within the design checklist for delivering high quality development so that the development accords with Policy DH1 of the Local Plan and other relevant policy and guidance.
Building heights
7.42. Paragraph 127 of the NPPF seeks to ensure that developments are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change.
7.43. Policy DH2 (Views and building heights) is focused on retaining significant views both within Oxford and from outside, with particular regard to the historic skyline of the City. Planning permission will not be granted for any building or structure that would harm the special significance of Oxford’s historic skyline.
7.44. The policy goes on to say that “planning permission will be granted for developments of appropriate height or massing, as demonstrated by the following criteria, all of which should be met:
. design choices regarding height and massing have a clear design rationale and the impacts will be positive; and
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Planning Statement Thornhill Park, London Road, Headington, Oxford
. any design choice to design buildings to a height that would impact on character should be fully explained, and the guidance on design of higher buildings set out in the High Buildings Study TAN should be followed. In particular, the impacts in terms of the four visual tests of obstruction, impact on the skyline, competition and change of character should be explained; and
. it should be demonstrated how proposals have been designed to have a positive impact through their massing, orientation, the relation of the building to the street, and the potential impact on important views including both in to the historic skyline and outwards Oxford’s green setting.”
7.45. The scheme comprises a series of residential buildings ranging in height from 3 to 6 storeys.
7.46. Feedback from the ODRP in December 2020 commented that the ambition for this development site is to deliver a significant number of new homes for the city – and that this means that this will be a high-density development. The buildings will therefore be highly visible, and the Panel commented that the new development is not something to hide; rather, that it should be celebrated, through exemplary design.
7.47. The wireframe drawings presented as part of the latest design review were considered by the Panel as helpful to understand the potential impact of these buildings from different viewpoints. Overall, following the advancement of the design, the ODRP believe the distribution of building heights across the site appears to better relate to the surrounding context, with the most significant buildings concentrated to the centre of the site, although they did recommend exploring further the mass in relation to the Risinghurst side of the site, where the existing housing is lower.
7.48. The further design iterations that respond to this feedback are set out in the DAS and the submitted drawings, and are now considered to respond fully to the design commentary; the building heights relate positively to the local context and meet the requirements of Policy DH2.
7.49. The overall impact of the scheme upon the wider landscape and visual amenities of the area are considered in the next section.
Landscape and Visual Impact
7.50. A Landscape and Visual Impact Assessment (LVIA), prepared by BMD, accompanies the application. The LVIA has been carried out in accordance with the Guidelines for Landscape and Visual Impact Assessment Third Edition (2013) (GLVIA3), and with reference to other technical notes.
7.51. The LVIA draws together the landscape and visual baseline information and summarises the key mitigation and enhancement measures, forming part of the iterative design process and maximising the positive influence of the proposed development on its surrounding context.
7.52. There LVIA explains that there are short distance partial and filtered views of the Site directly available from the adjacent residential properties on Downside End, Downside Road, and from the Shotover Long Distance Footpath along the Site’s eastern boundary. Users of the Risinghurst Cricket Club grounds will also experience full, near distance, partially filtered views towards the proposed development along the
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Site’s southern boundary, due to the prominence of built form along this edge and the more sparse nature of boundary vegetation currently present. There are middle distance views from residential properties on the eastern edge of the Forest Hill Conservation Area and users of Shotover Registered Park and Garden where the proposed development exceeds the height of the mature boundary tree canopies and the upper storeys will be visible, slightly extending the visible eastern edge of Oxford southwards.
7.53. Other than those noted above, middle distance to long distance views of the Site and proposed development are screened or heavily filtered by intervening wooded vegetation, either along the A40 dual carriageway to the north, the existing built form on the eastern edge of Oxford, and by existing landform to the south. In the long distance, views of the Site and Proposed Development are barely perceptible, very limited or there are no views at all.
7.54. The potential impacts upon the physical landscape resources of the Site are considered to be beneficial due to the establishment of tree and shrub planting, the increase in vegetation coverage and the incorporation of various habitats and ponds.
7.55. The landscape and visual effects have been assessed following three stages: during construction; immediately on completion (Year 0); and during operation after establishment of landscape mitigation (Year 15).
7.56. The LVIA identifies that, whilst there will be temporary and short term minor adverse landscape and visual effects, the long term landscape effects of the scheme are assessed as minor beneficial, or at worst negligible in their magnitude. The long term visual effects are also assessed as minor adverse in the context of users of the footpath and nearest properties, but that overall the visual effects will improve over the longer period of operation as the development will be seen within a well-established and vegetated landscape setting.
7.57. Shotover Registered Park and Garden is located c. 1.5km east of the Application Site. The LVIA indicates that Park users experience filtered long distance views towards the Site with intervening mature vegetation associated with the eastern Site boundary largely screening and filtering views of the Site. Views of the Proposed Development are, it states, likely where the built form exceeds the heights of the eastern boundary vegetation with the upper storeys and rooftops being visible above the tree canopies.
7.58. However, for the most part, the LVIA indicates that the intervening vegetation will filter and screen views of the Proposed Development from the Park. This includes the additional screening that is provided in the view from Downside End.
7.59. Due to the small scale of the Site and Proposed Development and extent of intervening vegetation and landform demonstrated in the Verified Views in Appendix G of the LVIA, the immediate to short term effects on views from the Park are ‘Minor Adverse’, but with mitigation are ultimately ‘Negligible Adverse’.
7.60. Based on the above summaries of the assessment, it is considered that the proposed development accords with the landscape and visual requirements of the adopted Local Plan policies and guidelines, and can be accommodated without giving rise to important material landscape and visual effects or harm.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Heritage
7.61. The accompanying Heritage Statement sets out the history of the site in the context of the proposed development and the features of historic importance that require assessment and mitigation subject to any impacts. The Statement discusses the significance of the site and its associations, and assesses the impact on affected heritage assets and views, and how they are experienced, as required by Policy DH3.
7.62. The assessment has identified that there are no heritage assets within the Site or wider study area whose significance would be affected as a result of changes to their setting resulting from the proposed development. This includes assessment of Shotover Park, a significant registered park & garden and associated mansion house and ancillary structures, which is located c.2km east of the application site and which has historic ownership links with Forest Lodge, the historic villa building within the site.
7.63. Detailed buildings assessment has clarified that two of the buildings within the Site, known as Forest Lodge and The Cottage, are of historic interest, and comprise ‘non-designated heritage assets’, but also that the change both to their fabric and surroundings provides a notable ‘capacity for change’.
7.64. The proposals retain the parts of the buildings of greatest significance, which is the original construction of Forest Lodge dating from the mid-19th century. The Heritage Statement considers that the proposed designs are thoughtful in their presentation of new architecture besides the old: in that the new Innovation Centre will be clearly distinct from the Victorian ‘villa’, but that it also provides an overall harmony through its use of architectural detail reflecting the ‘Italianate’ Picturesque of the building.
7.65. It is acknowledged that the proposals result in a level of harm to the buildings, which has been examined and summarized in the heritage assessment, but also provides some enhancement, notably in the long- term sustaining of the core structure of Forest Lodge.
7.66. Policy DH3 (Designated Heritage Assets) of the Local Plan encourages development to respect and draw inspiration from Oxford’s unique historic environment, responding positively to the local character and distinctiveness. The policy states that great weight will be given to the conservation of an affected designated heritage asset and to the setting of the asset where it contributes to that significance of appreciation of that significance. Where a development proposal will lead to less than substantial harm to a designated heritage asset, the policy requires this harm to be weighed against the public benefits of the proposal.
7.67. Section 16 of the NPPF notes the importance of designated heritage assets and features of national or international importance such as Listed Buildings and Conservation Areas. The NPPF notes a requirement for development to preserve and enhance the character and appearance of Conservation Areas and requires assessments of the impacts of development upon the significance of heritage assets.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.68. Paragraph 192 of the NPPF states that local planning authorities should take account of the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation when determining planning applications. In addition the desirability of new development making a positive contribution to local character and distinctiveness should be taken account of.
7.69. The PPG provides advice on the key points to take into account in relation to design matters. It reaffirms the advice given by the NPPF, that protecting and enhancing the historic environment is an important component of sustainable development. The guidance sets out that, in decision-taking, being able to properly assess the nature, extent and importance of the significance of a heritage asset, and the contribution of its setting, are very important to understanding the potential impact and acceptability of development proposals.
7.70. Paragraphs 193 – 198 of the NPPF set out how the harm to heritage assets from new development proposals should be assessed. Paragraph 196 states that “Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.”
7.71. The Heritage Statement explains that the proposed designs are thoughtful in the presentation of new architecture besides the old: the new Innovation Centre will be clearly distinct from the Victorian ‘villa’, but provides an overall harmony through its use of architectural detail reflecting the ‘Italianate’ Picturesque of the building. It is accepted, in the Heritage assessment that the proposals result in a level of harm to the buildings, but that they also provides some enhancement, notably in the long-term sustaining of the core structure of Forest Lodge.
7.72. Overall the Heritage Statement concludes that, as per the NPPF para 197, this harm should be weighed in the planning balance; the building, which is of modest value, is not proposed to be lost and is actually proposed to be conserved (a heritage benefit); the low level of harm identified will be non-physical and related to setting, which is already much compromised. Finally, the assessment has offered heritage- led design recommendations to support the client in achieving a sensitive and contextually inspired scheme. the heritage benefits of the scheme outweigh the minor instances of adverse impact.
7.73. It is recommended that if planning permission is granted, a ‘Level 4’ building record of The Cottage and the northern extension of Forest Lodge would be appropriate prior to removal. This would record the structural elements, with a report which would be publically accessible.
7.74. The proposals will result in heritage benefits in the overall planning balance, which are considered to outweigh the minor adverse impact identified in two long distance views, as referred to in the LVIA. As set out above this impact has been substantially mitigated through the design.
7.75. Considering the above the proposal accords with paragraph 192-198 of the NPPF, the requirements of Policy DH3 of the Oxford Local Plan and the Planning (Listed Buildings and Conservation Areas) Act 1990.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Archaeology
7.76. Policy DH4 (Archaeological Remains) of the Local Plan requires that, where archaeological deposits and features are suspected to be present, the application should include sufficient information to define the character, significance and extent of such deposits so far as reasonably practical.
7.77. The Heritage Assessment includes consideration of the archaeological potential of the site, and provides an assessment of the likely impacts of previous development on the survival of any archaeological remains and assesses the potential for impacts from the proposed development on the surviving archaeological resource.
7.78. The Archaeological assessment and geophysical survey have not found evidence for below-ground archaeological remains, and no such known remains would be impacted upon by the proposals. However, a Written Scheme of Investigation for trial trenching, prepared by Cotswold Archaeology, has been agreed with the city archaeologist, which will be carried out during the application determination period, to ensure that a suitable level of information on the below-ground resource is provided, and that the grant of any permission can be suitably conditioned to deal with any features of interest that may arise.
7.79. Any required archaeological mitigation will therefore be discussed with the city archaeologist on completion of the archaeological trial trenches.
Transport
7.80. Paragraph 108 of the NPPF states that development should:
. Provide appropriate opportunities to promote sustainable transport modes; . Provide safe and suitable access to the site for all users; and . Mitigate any significant impacts from the development on the transport network.
7.81. Paragraph 111 requires developments to give priority to pedestrian and cycle movements, address the needs of people with disabilities, create places that are safe, secure and attractive, allow for the efficient delivery of goods, and access by service and emerging vehicles.
7.82. Policy RE7 (Managing the impact of development) seeks to ensure development does not have unacceptable transport impacts affecting communities, occupiers, neighbours and the existing transport network.
7.83. Policy M1 (Prioritising walking, cycling, and public transport) outlines in detail the Council’s approach to prioritising movement by foot, cycle or public transport. The policy promotes walking in the city through meeting the needs arising from development and taking opportunities to achieve improvements. Proposals should ensure that the urban environment is permeable and safe to walk through and adequately lit, with good and direct connections both within and across the wider network. Improvements to the pedestrian environment may include the provision of high quality crossing points where needed, seating, signage and landscaping.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.84. There are a number of opportunities to increase the accessibility and permeability of the site by upgrading the existing routes and opening up a new pedestrian access route through the site. Segregated pedestrian footpaths are provided across the proposed development, to provide pleasant, traffic free routes working their way north to the existing A40 walking and cycling network. Changes in surfacing provide indicative crossing points along key desire lines throughout the site. A footpath link is also proposed to the west into the adjacent residential area of Risinghurst, whilst a link to the existing footpath to the south, connecting to Grovelands Road, is also maintained.
7.85. The site will continue to be serviced by one main vehicular access point from the A40, albeit the new access will have a wider splay in terms of access and egress lane and represents betterment in that regard. The existing vehicular access will be closed to vehicles, but retained for pedestrians and cyclists, again improving the overall permeability for those modes.
7.86. In order to promote cycling in the city and ensure an accessible environment for cyclists, Policy M1 seeks to ensure development “provides for connected, high quality, convenient and safe cycle routes … [and] accessible, conveniently located, secure cycle parking facilities in both private and publicly-accessible locations [and]…) makes provision for high quality on-site facilities that promote cycle usage, including changing rooms, showers, dryers and lockers…”.
7.87. Policy M2 (Assessing and managing development) requires the application to be accompanied by a Transport Assessment, Travel Plan and Construction Management Plan. These documents have been submitted in support of this application, in accordance with Policy M2.
7.88. The accompanying Transport Assessment has been prepared in accordance with Appendix 7 of the Local Plan and in accordance with a scope agreed with Oxfordshire County Council Highways which takes account of all highway users.
7.89. A Stage 1 Road Safety Audit of the A40 has also been carried out which confirms the safety of the proposed new highway junction.
Sustainable Modes of Transport
7.90. The application site is highly accessible by sustainable modes of travel being on a main arterial route, adjacent to the Thornhill Park & Ride, and with easy access to Headington and Oxford city centre.
7.91. The proposals include an extensive amount of cycle parking in accessible and convenient locations for residents, and users of the commercial and hotel buildings, as discussed further below.
7.92. The external areas have been designed to be as accessible as possible and further details on accessibility are provided within the DAS.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Car Parking
7.93. Car Parking provision is considered in Policy M3, which states that for residential schemes 400m walk to frequent (15minute) public transport services and within 800m walk to a local supermarket or equivalent facilities (measured from the mid-point of the proposed development) planning permission will only be granted for residential development that is car-free.
7.94. Policy M3 also states that “…The parking requirements for all non-residential development … must take into account the objectives of this Plan to promote and achieve a shift towards sustainable modes of travel. The presumption will be that vehicle parking will be kept to the minimum necessary to ensure the successful functioning of the development… In the case of the redevelopment of an existing or previously cleared site, there should be no net increase in parking on the site from the previous level and the Council will seek a reduction where there is good accessibility to a range of facilities”
7.95. The site does adjoin a major public transport route and interchange, but there are very limited local retail facilities in the locality. In any case, this proposal only incorporates very limited parking, as described in Section 4, comprising 95 unallocated residential parking spaces, including 20 disabled persons spaces. The Transport Assessment highlights that this level of provision will help to suppress car ownership, and the level of private car trip generation emanating from the site.
7.96. Policy M4 (Provision of electric charging points) relates to both residential and non-residential development that include parking spaces. This proposal therefore incorporates charging points based on a ratio of 25% and including the car club spaces.
Cycle Parking
7.97. Policy M5 (Bicycle parking) provides full details of the Council’s expectations regarding bicycle parking, stating, “Planning permission will only be granted for development that complies with or exceeds the minimum bicycle parking provision [standards]… Bicycle parking should be, well designed and well- located, convenient, secure, covered (where possible enclosed) and provide level, unobstructed external access to the bicycle parking should be designed to accommodate an appropriate amount of parking for the needs of disabled people, bicycle trailers and cargo bicycles... For new non-residential development, the City Council will seek the provision of showers and changing facilities…”
7.98. A mix of secure covered cycle parking is provided, for residents, the hotel and Innovation Centre, alongside unsecure visitor cycle parking, as follows:
. Secure residential covered - 928 spaces . Secure non-residential covered - 88 spaces . Unsecure visitor spaces within the public realm – 402 spaces . Total – 1,418 spaces
7.99. Details of the locations of these spaces are provided on the submitted drawings. The visitor cycle stands are well distributed across the scheme, and 30% of those are covered.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.100. Appendix 7.4 of the Local Plan sets out the minimum bicycle parking standards, although some uses do not have a designated level, but are to be determined on the merits of the case.
7.101. Paragraph 4.7 of the Transport Assessment indicates that the scheme is in accordance with the requirements of the Oxford Local Plan 2036 local standards.
Impact of Proposed Development on Highways
7.102. The Transport Assessment sets out the following main conclusions;
. an assessment of vehicular trip generation and associated analysis has demonstrated that the proposed development is likely to have a minimal impact on the local highway network;
. it has been shown that the uplift compared to the original AC Nielsen development is relatively minor, with an average weekday uplift of just 30 and 33 two-way vehicle trips during the AM peak and PM peak hour periods respectively;
. analysis has shown that throughout the majority of the daytime the hotel's car park is likely to cope with demand, with no overspill demand likely to occur during the working day at the Park & Ride;
. the hotel car park only reaches capacity between 18:00 and 19:00. Hotel guests are therefore only likely to seek to park in the Park & Ride after the network peak period of 17:00 to 18:00. A relatively small number of cars are likely to accumulate at the Park & Ride into the evening, when demand for spaces at the Park & ride will otherwise be largely reducing, leaving the following morning;
. a junction capacity assessment has demonstrated that the proposed access arrangement will operate with spare capacity in the assessment year of 2026; and
. when expressed as a percentage of the total flow along the A40, the impact of the development is low and unlikely to result in a perceptible impact on the Headington Roundabout and further afield.
7.103. The development will therefore not have unacceptable transport impacts, and there is capacity within the network for the increased pedestrian and cycle flows.
7.104. Servicing and delivery vehicles will use the new access and internal road network, and the design layout has taken account of the requirements for manoeuvring of waste vehicles.
7.105. Based on the information set out in the TA, and when assessing the proposal in the context of the National Planning Policy Framework (2019), it is concluded that there will be no severe residual cumulative impacts resulting from the development nor an unacceptable impact on highway safety and that, accordingly, this application should not be prevented or refused on highways grounds.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.106. Overall, the proposals seek to promote sustainable transport modes, provide safe and suitable access for all users and mitigate any impacts on the transport network. The proposals therefore accord with the relevant parts of Policy RE7, policies M1, M2, M3 and M5 of the Local Plan 2036 and paragraphs 108 and 111 of the NPPF.
Sustainability
7.107. Policy RE1 (Sustainable design and construction) states:
“Planning permission will only be granted where it can be demonstrated that the following sustainable design and construction principles have been incorporated, where relevant:
. Maximising energy efficiency and the use of low carbon energy; . Conserving water and maximising water efficiency; . Using recycled and recyclable materials and sourcing them responsibly; . Minimising waste and maximising recycling during construction and operation; . Minimising flood risk including flood resilient construction; . Being flexible and adaptable to future occupier needs; and . Incorporating measures to enhance biodiversity value.”
7.108. The policy then sets out requirements in relation to energy statements, carbon reduction, heat networks and water efficiency.
7.109. This application is supported by a comprehensive Energy Statement, as required by Policy RE1, and a Sustainability Statement which reflects the new policy requirements of the Local Plan 2036. The following section on energy addresses the energy specific parts of Policy RE1. This is followed by sections on the Sustainable Design and Construction Principles as listed above and water efficiency.
Energy
7.110. Policy RE1 also concerns itself with carbon reduction in new large scale commercial buildings. The policy requires development proposals to meet BREEAM excellent standard (or recognised equivalent assessment methodology) in addition to reductions in carbon emissions. Development proposals of 1,000m2 or more should achieve at least a 40% reduction in the carbon emissions compared with a 2013 Building Regulations (or future equivalent legislation) compliant base case. This reduction is to be secured through on-site renewables and other low carbon technologies and/ or energy efficiency measures.
7.111. In addition, Policy RE1 encourages the development of city wide heat networks. The policy states that if a heat network exists in close proximity to a scheme it is expected to connect to it and this will count towards the development’s carbon reduction requirements.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.112. The Energy Statement sets out how the scheme is seeking to meet the requirements of Policy RE1. Through a combination of passive and energy efficient measures, and low or zero carbon technologies, the
scheme should achieve a 40% reduction in regulated CO2 emissions compared to a Part L Building Regulations compliant baseline.
7.113. The electricity grid has experienced a dramatic reduction in carbon intensity since 2013, when the latest version of Part L was released. To reflect this, and to inform the carbon factors in the next update of the Building Regulations, the BRE published in 2018 the Draft SAP10.0 carbon factors. A further update of these carbon factors was released by the BRE in October 2019 (SAP 10.1), bringing the carbon factor of electricity more in line with what is expected to be the grid electricity in the coming years.
Sustainable Design and Construction Principles
7.114. The sustainability strategy for the proposed development sets out how the proposals for the Site perform against the following key points:
. Local Planning Policies . Sustainable Design benchmarks – e.g. WELL Building Standard . A selection of Best Practice Industry Standards – e.g. BREEAM New Construction 2018, CIBSE Guidelines.
7.115. The approach to the incorporation of the sustainability measures within the scheme has been agreed through pre-application discussions with officers at Oxford City Council.
7.116. The following table discusses how each of the sustainable design and construction principles have been incorporated into the proposed development:
Policy Requirement Proposals Energy: Maximising energy efficiency and
the use of low carbon energy Low water consuming sanitary ware will be specified to ensure that the potable water consumption of the building is kept to a minimum. Water meters will be incorporated on the main water Water: Conserving water and maximising supply of each building as well as to each water water efficiency consuming plant or areas representing over 10% of the building's total water demand to allow the building occupants to keep track of their consumption and therefore promote water saving behaviours. Recycled materials: Using recycled and Elements of the existing buildings on site and recyclable materials and sourcing them surrounding external infrastructure are being retained responsibly and reused for the new development.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
The use of recycled aggregates from off-site sources will be promoted with an aspiration to use these for a significant proportion of all aggregates consumed on site. The use of recycled or reclaimed timber will be promoted with an aspiration to uses this for a significant proportion of all timber used on site. The use of recycled insulation products will also be promoted. The selected contractor will be required to minimise Waste: Minimising waste and maximising waste and maximise the recycling of waste. recycling during construction and operation
The site lies within flood zone 1, the area with the lowest probability of flooding. The proposals include Flooding: Minimising flood risk including Sustainable Drainage Systems which will result in a flood resilient construction reduction in the discharge rate in comparison with the current level of run-off. Flexibility and adaptability: Being flexible Long term adaptability has been achieved through the and adaptable to future occupier needs design proposals. Numerous biodiversity enhancement measures are Biodiversity: Incorporating measures to proposed to enhance biodiversity on the site. These enhance biodiversity value are discussed in more detail within the biodiversity section below.
Water Efficiency
7.117. In relation to water efficiency, policy RE1 requires proposals to meet the minimum standard of four credits under the BREEAM assessment. The proposals have been designed to limit the use of potable water as far as possible, through the specification of sanitary ware and by specifying low flow rate products.
7.118. All indoor and outdoor planting will be chosen to be suitable for the UK climate and therefore rely mainly on precipitation, therefore designing out any need of irrigation.
7.119. Water meters will be incorporated on the main water supply to the buildings.
Health and wellbeing
7.120. Policy RE5 (Health, wellbeing, and Health Impact Assessments) seeks to promote strong, vibrant and healthy communities and reduce health inequalities. The policy requires developments to incorporate measures that will achieve these aims.
7.121. As required by the policy, a Health Impact Assessment (HIA), prepared by Savills, accompanies this application. This utilises the NHS Healthy Urban Development Unit Rapid HIA tool, as agreed with OCC.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.122. The health and wellbeing of the residents and building users has been integral to the design development of the buildings and spaces, and was highlighted by the ODRP as a critical strand of the place making strategy. The design ensures that users have access to nature, daylight and views which are all critical to enhancing occupant’s wellness as well as productivity and creativity.
7.123. The proposals incorporates new landscape and on site facilities, including a gym, designed to improve and enhance wellness. The layout of the scheme also aims to foster community and generate engagement through the public realm and shared spaces.
7.124. The accompanying HIA sets out the likely health impacts of the development proposals, in the context of the location, and health data for the local ward and the wider city, and recommends measures to address any negative impacts. The relevant topics considered in the HIA fall into the following categories:
i. Access to healthcare services and other social infrastructure ii. Access to open space and nature iii. Air quality, noise and neighbourhood amenity iv. Accessibility and active travel v. Crime reduction and community safety vi. Access to healthy food vii. Access to work and training viii. Social cohesion and lifetime neighbourhoods ix. Minimising the use of resources x. Climate change
7.125. The HIA highlights the following key components that will be provided by the scheme;
. A high quality of urban design, addressing the needs of all people, encouraging social cohesion and the creation of ‘lifetime neighbourhoods’ . Access to open space and nature . Encouraging active travel and high levels of accessibility for sustainable movement . Safeguarding air quality and amenity, and limiting pollution . Access to healthcare services and other social infrastructure . A safe environment, with the reduced risk of crime . Access to healthy food . Access to work and training . Minimising the use of non-renewable resources and supporting the climate change agenda through improving energy efficiency
7.126. The design and layout of the building aims to stimulate people’s movement via stairs instead of lifts by providing walkable routes along desire lines and by locating shared enjoyable facilities and amenities at various points throughout the building rather than in one place, adding physical activity to an occupant’s day. At the same time the arrangement of lifts ensures that all building areas remain fully accessible and within easy reach to anyone who cannot negotiate stairs.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.127. Legibility and the ability to quickly orientate and understand a space are also key to enhancing enjoyment and reducing stress. The design and layout of the spaces and buildings ensures they are easy to navigate and views to external spaces and natural features are provided.
7.128. During the construction process the development will generate direct employment. In addition, the presence of construction workers would have an indirect impact on the local economy associated with their expenditure in local businesses therefore have a positive effect on the local economy.
7.129. Overall, upon completion, the development is expected to result in a number of beneficial effects including improving access to greenspace, providing a living and working environment that enhances the wellness of users and encourages engagement and providing opportunities for public engagement and outreach to surrounding neighbourhoods, who will also be able to enjoy the shared public realm.
7.130. The proposed development will enhance the experience and wellness of users and will have a number of socio-economic benefits for residents and users, the wider public and local economy during both construction and operation, in line with Policy RE5.
Drainage
7.131. Policy RE3 (Flood Risk Management) encourages new development to be directed towards areas of low flood risk (Flood Zone 1).
7.132. Policy RE4 (Sustainable and foul drainage, surface and groundwater flow) requires all development proposals to manage surface water through Sustainable Drainage Systems (SuDS) or techniques to limit run-off and reduce the existing rate of run-off on previously developed sites. The policy requires that surface water runoff is managed as close to its source as possible, in line with the following drainage hierarchy:
a) store rainwater for later use; then: b) discharge into the ground (infiltration); then: c) discharge to a surface water body; then: d) discharge to a surface water sewer, highway drain or other drainage system; and finally: e) discharge to a combined sewer.
7.133. Paragraph 165 of the NPPF also requires major developments to incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.
7.134. The Site is located within Zone 1, and therefore at low risk from fluvial flooding. However, as the Site is larger than 1 ha in area a Flood Risk Assessment (FRA), prepared by Cole Easdon, accompanies this planning application, in order to consider how the development accords with national guidance and Policy RE3.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.135. The FRA indicates that the site also remains at low flood risk from onsite watercourse/ditches, sewers and groundwater; limited surface water ponding occurs within the low lying north western region where water appears to accumulate behind the A40 embankment. Risk of surface water flooding will be dealt by the provision of a suitable outfall for the existing watercourse, appropriate overland flow route including de- culverting of the piped watercourse channel, raised floor levels, regular maintenance of the onsite watercourse/ditch and appropriate adequate drainage/SuDS system.
7.136. As required by the policy, a Drainage Strategy, prepared by Cole Easdon, also accompanies this planning application which has had regard to the Oxfordshire County Council guidance for major development. The strategy provides details on the proposed sustainable drainage system, existing and proposed run-off rates, details on the management and maintenance of the drainage system and the proposed foul drainage strategy.
7.137. The SuDs strategy is based on using the existing site characteristics and landform to maximum effect. The ditches running north south and east west will be utilised and opened up for attenuation and bio-retention. Rain gardens will be incorporated and biodiverse, green and amenity roofs will aid the drainage design. Also, permeable parking will be a feature running through the site and attenuation combined with new tree pits is a potential opportunity.
7.138. The development site currently generates brownfield runoff of 93 l/s in the 1 year event with 292 l/s in the 100 year event. The proposed development will comprise approximately 1.57 ha of impermeable area, including the extended Lodge House, an increase of 0.59 ha hard area over the current situation. However, most of the roof areas (0.437ha) will include green roofs, and roads/parking areas will be permeable. Along with the incorporation of storage basins, rain garden corridors and open ditches, surface water runoff generated from the developed site will be reduced to minimal rates, utilising these sustainable drainage measures.
7.139. The Drainage Strategy outlines the Sustainable Drainage systems that have been chosen for the site based on their suitability, coordination with the landscape proposals, the proposed ground levels and proximity to existing buildings. The proposed surface water drainage solution maximises SuDS opportunities across the development to provide suitable attenuation and produce no flood risk for or from the site.
7.140. Policy RE4 also requires that development does not have an adverse impact on groundwater flow. The assessment confirms that the groundwater table is at 16-17m depth, and that proposals will have no impact on groundwater, in terms of flow or flood risk from ground water.
7.141. In relation to foul drainage, Policy RE4 encourages developers to separate foul and surface water sewers on all brownfield sites. The Drainage Strategy sets out the site wide foul water strategy which is separate from surface water drainage. For further information on the proposed foul drainage strategy, please refer to section 4.23 to 4.28 of the accompanying Drainage Strategy.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.142. The proposed Drainage Strategy follows the Oxfordshire County Council and Oxford City Council drainage guidance and accords with Policies RE3 and RE4 of the Oxford Local Plan 2036 as well as paragraphs 163 and 165 of the NPPF.
Ecology
7.143. Policy G2 (Protection of biodiversity and geo-diversity) requires compensation and mitigation measures to achieve an overall net gain for biodiversity, and ensure protection. In addition, Policy RE1 (Sustainable design and construction) requires proposals to incorporate measures to enhance biodiversity value.
7.144. Paragraph 175 of the NPPF states that development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around development should be encourage, especially where this can secure measurable net gains in biodiversity.
7.145. The application is accompanied by a preliminary (Phase 1) ecological appraisal, by Greengage, which seeks to establish the ecological value of the Site and the presence/likely-absence of notable and/or legally protected species in order to inform appropriate mitigation, compensation and enhancement actions in light of the proposed development works.
7.146. Key findings of the ecological appraisal confirm that the Site has the potential to support the following protected / notable species;
. High potential to support roosting bats;
. Moderate potential to support foraging and commuting bats;
. High potential to support great crested newts within the terrestrial habitat on site and within the pond just outside of the red line boundary;
. Moderate potential to support reptiles;
. Moderate potential to support hedgehog; and
. High potential to support nesting birds.
7.147. Recommendations have therefore been provided for additional Phase 2 surveys, to be completed for bats, reptiles, and great crested newts, with precautionary actions recommended for breeding birds. Preliminary protection, mitigation, compensation and enhancement concepts are outlined within the report, to be confirmed following the Phase 2 survey work, with a view to the scheme achieving a net biodiversity gain.
7.148. Further to these mitigation and compensation actions, it is recommended that the site’s ecological value is enhanced through the incorporation of:
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Planning Statement Thornhill Park, London Road, Headington, Oxford
. Wildlife friendly landscaping;
. Biodiverse living roofs;
. Vertical greening;
. Invertebrate habitat features (e.g. bee bricks and stag beetle loggery); and
. Bird and bat boxes integrated within the fabric of new buildings, as well as on retained trees.
7.149. A Biodiversity Net Gain Assessment was also undertaken by Greengage (the Phase 1 appraisal), which demonstrates that the development proposals will result in a net gain.
7.150. The proposals incorporate green roofs. These will be designed to support a wildflower blanket biodiverse green roof capable of supporting a range of wildflower and insect species. The provision of wildflower based green roofs will promote invertebrate diversity at site level and contribute towards the Pollinator Action Plan within the Oxford City Council Biodiversity Action Plan 2015 – 2020.
7.151. All of the above key actions will be detailed within an Ecological Management Plan (EMP) for the Site, which could be secured through planning condition. Should these recommendations be adhered to, the proposals stand to be compliant with legislation and current planning policy.
7.152. The proposals therefore include the opportunity for biodiversity enhancement measures that will provide a net gain. Subject to the production of the EMP and enhancement strategies, the development is capable of according with the relevant biodiversity principle of Policy RE1, Policy G2 of the Local Plan and paragraph 175 of the NPPF.
Trees
7.153. Paragraph 175 of the NPPF seeks to ensure that significant harm to biodiversity resulting from a development is adequately mitigated or compensated for.
7.154. Policy G7 (protection of existing Green Infrastructure features) of the Local Plan states that planning permission will not be granted for development that results in the loss of green infrastructure features such as hedgerows, trees or woodland where this would have a significant adverse impact upon public amenity or ecological interest. It must be demonstrated that their retention is not feasible and that their loss will be mitigated. The policy states that planning permission will not be granted for development resulting in the loss of trees, except in the following circumstances:
a) “it can be demonstrated that retention of the trees is not feasible; and b) where tree retention is not feasible, any loss of tree canopy cover should be mitigated by the planting of new trees or introduction of additional tree cover (with consideration to the predicted future tree canopy on the site following development); and
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Planning Statement Thornhill Park, London Road, Headington, Oxford
c) where loss of trees cannot be mitigated by tree planting onsite then it should be demonstrated that alternative proposals for new Green Infrastructure will mitigate the loss of trees, such as green roofs or walls.”
7.155. The application is accompanied by an Arboricultural Impact Assessment (AIA), prepared by Lockhart Garratt and all works will be done in liaison with City Council officers.
7.156. The survey identifies a total of 72 trees, 22 groups of trees and 1 hedgerow within the Site. The existing trees have been categorised as follows:
. 22 of good arboricultural quality (Category A) . 48 of moderate arboricultural quality (Category B) . 16 of low arboricultural quality (Category C) . 9 of poor arboricultural quality (Category U)
7.157. The development proposal will require the removal, or partial removal, of 22 trees, groups of trees or hedgerows. Seven of these trees would be recommended for removal anyway, irrespective of this proposal, due to poor physiological and structural condition. The remaining 15 comprise a mix of moderate and low arboricultural quality trees. These trees are proposed for necessary removal to facilitate the construction of the new buildings, internal access roads, new car parking, drainage or new landscaping.
7.158. The scheme involves the retention of 77 trees or groups of trees (81%) and no high quality specimens are proposed for removal to facilitate this proposal.
7.159. The tree canopy cover assessment included within the AIA indicates that there will be an increase in canopy cover area as a result of the development proposal, in comparison to a no development scenario over a 30 year period, and that the tree cover will increase by 2.5% over that period compared to the no development scenario.
7.160. All trees being retained within, or directly adjacent to the site, will be protected through a combination of measures. This primarily consists of tree protective fencing, although permanent ground protection in the form of ‘no-dig’ construction, temporary ground protection in the form of load-bearing matting, and supervised excavations for the drainage strategy, will also be required.
7.161. The proposal therefore accords with Policy G7 of the Local Plan 2036 and paragraph 175 of the NPPF.
Air quality
7.162. Policy RE6 (Air Quality) states that planning permission will only be granted where the impact of new development on air quality is mitigated and where exposure to poor air quality is minimised or reduced. As required by policy RE6, the application is accompanied by an Air Quality Assessment (AQA) prepared by GEM Air, which considers the air quality impacts of the proposal, primarily from construction and vehicle emissions.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.163. The change in predicted particulate matter and NO2 concentrations at existing receptors, in 2026 following completion of the proposed development, is considered negligible. Overall, with the limited provision for vehicles on site, and the move towards electric vehicles, and the move away from gas fired central heating, air quality is a low priority consideration with regards to the impact of the proposed development. Air quality at the site and in the vicinity of the site will therefore remain good.
7.164. A qualitative assessment of dust levels associated with the proposed development has been carried out. The impact of dust soiling and particulate matter during construction can be reduced to negligible through appropriate mitigation measures, which are listed in Table 19 of the AQA. Implementation of Best Practice Measures, including a Dust Management Plan, secured by condition will help reduce the impact of the construction activities to an acceptable level.
7.165. With these control measures and mitigation in place, the likelihood of nuisance dust episodes occurring at sensitive receptors adjacent to the development are considered low.
7.166. Overall, it is considered that the proposed development would not result in significant effects on air quality. The development therefore accords with Policy RE6 of the local plan and paragraph 181 of the NPPF
Noise
7.167. Policy RE8 (Noise and vibration) states that planning permission will only be granted for development proposals which manage noise to safeguard or improve amenity, health and quality of life.
7.168. Paragraph 170 of the NPPF states that planning policies and decisions should contribute to and enhance the natural and local environment, including by preventing development from contributing to unacceptable noise pollution. Paragraph 180 states that new development should be appropriate for its location taking into account the likely effects of pollution on health, living conditions and the natural environment.
7.169. A Noise Assessment, prepared by Hann Tucker, accompanies this submission. The assessment establishes the currently prevailing environmental noise climate around the site, the existing and proposed sources and receptors, and a 3D noise model has been created, using the data obtained from noise survey work.
7.170. The environmental noise impact upon the proposed dwellings has been assessed in the context of national and local planning policies, and appropriate target internal noise levels have been proposed. The report comments that these are achievable using conventional mitigation measures.
7.171. Mitigation advice, including the use of suitably specified glazing and acoustically attenuated ventilation, has been recommended to reduce to a minimum the adverse impact on health and quality life arising from environmental noise.
7.172. The proposals therefore include mitigation that can be managed through detailed design and conditions to control any intrusive noise and ensure that the delivery of the proposals safeguards the amenity and health of the identified receptors.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.173. The assessment demonstrates that the site, subject to appropriate mitigation measures, is suitable for residential development in terms of noise. Thus, the proposals are in accordance with Policy RE8 of the Local Plan and paragraphs 170 and 180 of the NPPF.
Contamination
7.174. Paragraph 178 of the NPPF requires that a site is suitable for its proposed use taking account of ground conditions and any risks arising from land stability and contamination.
7.175. Policy RE7 (Managing the impact of development) requires land contamination to be considered when ensuring the amenity of communities, occupiers and neighbours is protected.
7.176. Policy RE9 (Land quality) requires that, where proposals would be affected by contamination, or where contamination may present a risk to the surrounding environment, a report must accompany a planning application demonstrating:
a) “details the investigations that have been carried out to assess the nature and extent of contamination and the possible impacts it may have on the development and its future users, biodiversity, the natural and built environment; and b) sets out detailed mitigation measures to allow the development to go ahead safely and without adverse effect, including, as appropriate: i. removing the contamination; ii. treating the contamination; iii. protecting and/or separating the development from the effects of the contamination; iv. validation of mitigation measures”
7.177. This planning application is accompanied by a Phase 1 Desk Study, prepared by Lustre, which considers the historic and current use of the Site, ground conditions, known and potential sources of contamination and potential risks, including to future receptors.
7.178. In terms of the geology and hydrogeology, Made Ground, up to 2m thick, has been recorded across the western section of the Site, whilst topsoil has been recorded across the majority of the eastern section of the site. British Geological Survey mapping records show the site to be underlain by Kimmeridge Clay Formation (unproductive strata) and Ampthill Clay Formation(unproductive strata), and the Wheatley Limestone Member (Secondary A Aquifer). No superficial deposits are anticipated on site, but a drainage ditch is noted to be present on the Site.
7.179. The following potential sources of contamination have been identified: a private Petrol Filling Station and associated below ground fuel storage, bulk above ground fuel storage (heating oil and diesel), an electricity substation, an infilled pond and historical demolition and construction works associated with the A.C Nielsen headquarters.
7.180. Previous intrusive investigation at the Site identified elevated concentrations of lead within the Made Ground, and localised petroleum hydrocarbon contamination associated with bulk fuel storage.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
7.181. In terms of conclusions on land quality and recommendations, the Phase 1 report identifies that there are presently unacceptable risks to future residents, site workers, visitors and potable water supply from historic contamination, demolition and construction works associated with the former A.C. Nielsen Headquarters and Forest Lodge and from potential contamination from the bulk above ground fuel storage, electricity substation, an infilled pond and small scale hazardous material storage on site. A Phase 2 Site Investigation is therefore recommended to further assess the identified risks, and consider more detailed approaches to mitigation.
7.182. A geotechnical investigation will also be required to inform foundation design. Potential ground stability hazards have been identified which may adversely impact the Site in terms of shrinking or swelling clay. Due to the presence of local quarrying activities, further assessment of the risk from extraction and mining features and quarry sites should also be undertaken.
7.183. It is anticipated that suitable mitigation can be achieved, in order to ensure that the proposals are accordance with Policy RE9 of the Local Plan, and paragraph 178 of the NPPF, but there will be requirements for further site intrusive work and reporting in order to inform this, and associated planning conditions.
Waste management
7.184. Policy RE1 (Sustainable design and construction) sets out a number of sustainable design and construction principles including "minimising waste and maximising recycling during construction and operation”.
7.185. The application is accompanied by a Waste Statement and Site Waste Management Plan (SWMP), prepared by Evoke, which identifies high level waste objectives for the site operation.
7.186. The SWMP sets the direction for a detailed SWMP, to be produced by the construction contractor, for management of construction waste associated with the proposed development. The waste objectives include managing waste as sustainably as possible and diverting as much waste as possible from landfill through prevention, reuse, recycling and recovery.
7.187. The waste streams anticipated to generate the largest volumes of waste, including concrete and soil, have a high potential to be diverted from landfill. The Applicant will adopt the recommendation measures made in line with the waste hierarchy. The proposed development would be constructed in a manner which aims to protect the environment and local community through reusing, recycling and recovering waste where ever practicable which would otherwise be disposed of at landfill.
7.188. The SWMP also identified the approach to waste management when the site is occupied. The aim of this document is to ensure that waste is efficiently managed in line with the waste hierarchy and relevant policy requirements.
7.189. These documents demonstrate how the proposals aim to minimise waste and maximise recycling during construction and operation ensuring the proposed development accords with the sustainable design and construction principles set out in Policy RE1 of the Local Plan.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
8. Planning balance and conclusions
8.1. This application seeks full planning permission for a new residential led mixed use development at Thornhill Park, in line with the adopted policy for the site, other relevant Development Plan policies and national guidance. The description of development is as follows:
Development of 402 apartments (Class C3), a 133 bed hotel (Class C1), employment provision in the form of an Innovation Centre, with additional mixed use accommodation to include office space, gym, café and restaurant (all within Class E), public open space, associated landscape and the provision of a new vehicular access onto the A40.
8.2. The principle of development is supported by Policy SP47 of the Local Plan, which supports proposals for residential development at the site, subject to the provision of retained employment and relocation of the sports ground.
8.3. The proposals seek to make efficient and effective use of this previously developed/brownfield site in line with Local Plan Policy RE2 and Section 11 of the NPPF. This has been achieved in a manner compatible with the Site itself and the surrounding area, and in accordance with other policies in the Plan.
8.4. The design of the proposals has been the subject of extensive pre-application engagement with the City Council’s officers, the Oxford Design Review Panel, key stakeholders and the wider community. As demonstrated by the Design and Access Statement and this Planning Statement, the proposals have been developed to consider all the feedback received through this engagement, which has led to the proposals now submitted.
8.5. This has resulted in a proposal that is of high quality design and meets the design objectives and principles set out within the adopted Oxford City Local Plan and national planning guidance.
8.6. Given the height and massing of the proposed buildings, the LVIA has assessed the impact of the development from agreed views points in terms of the four visual tests of obstruction, impact on the skyline, competition and change of character. The assessment has shown that the impacts are minor, and over time would be negligible.
8.7. The Heritage Statement has made an assessment of the heritage impact of the proposed development on heritage assets and their setting. The assessment finds that the heritage benefits of the scheme outweigh the minor instances of adverse impact upon heritage assets.
8.8. The Site is in a highly sustainable location and prioritises movement by foot, cycle and public transport. The Transport Statement has demonstrated that the import on the highway network will be minor and that this will be mitigated by the approach to support active travel and reduce car borne movements. The proposals provide for limited car parking and the proposals for cycle parking are aligned with the Council’s standards.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
8.9. Sustainability has been a key priority for the project and the proposals have been developed to meet high sustainability standards, and to meet a 40% reduction in carbon emissions in accordance with Policy RE1. In addition, the proposals have sought to meet the sustainable design and construction principles set out within this policy. This has included:
. Using passive and energy efficiency measures, heat pumps and PV panels to achieve a 40% regulated carbon emission reduction; . Connecting to the heat network; . Maximising water efficiency; . Promoting the use of recycled materials, minimising waste and maximising recycling during construction and operation; . Incorporating sustainable drainage systems to result in a betterment in run off rates on the site; . Incorporating biodiversity enhancement measures on the site to increase its biodiversity value; and . Designing buildings that offer future flexibility and adaptability.
8.10. The NPPF, at paragraph 8, states that there are three dimensions to sustainable development: economic, social and environmental. The economic and social dimensions will be achieved through enabling the proposed sustainable growth at Thornhill Park and the allocation of the site in the Local Plan recognises that this growth will maximise the economic, social and cultural benefits that the re-use of this site will bring to Oxford. In addition, the proposals provides a greatly enhanced new neighbourhood, with space to live, work, play and for neighbouring communities and visitors to Oxford to enjoy.
8.11. As set out above, the proposal will also bring substantial environmental benefits including providing new area of public realm, a betterment in surface water runoff rates, creating buildings that are energy efficient and set within a landscape that enhances biodiversity.
8.12. In line with the NPPF, any harm associated with this proposal must be weighed against the benefits of the proposal. Once this planning balance is undertaken, it can be concluded that the numerous and substantial benefits of this proposal comfortably outweigh any limited harm that has been identified. On this basis, and in-line with the guidance of the NPPF, it is respectfully requested that the application is approved.
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Appendices
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Planning Statement Thornhill Park, London Road, Headington, Oxford
Appendix 1.0 EIA Screening Opinion
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Planning Services St Aldate’s Chambers 109 – 113 St Aldate’s Oxford OX1 1DS
Central Number 01865 249811
Dawn Brodie Wytham Court 11 West Way OXFORD OX2 0QL
By email [email protected]
3 November 2020
Dear Dawn
Thornhill Park
The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended): Regulation 6: Request for Screening Opinion
I write in response to your letter dated 6 October 2020 which requests a Screening Opinion as to whether an Environmental Impact Assessment (EIA) is required to accompany a planning application for a residential-led mixed use development on the site identified in the supplied site location plan, reference SK069.
Thank you for your email of 27 October 2020 which confirms an extension of time to the original 21 day deadline.
The 3.34 hectare site lies approximately five kilometres to the east of Oxford city centre, and is bounded to the east by Thornhill Park and Ride and the residential conversion of the former Nielsen House office building, to the north by the A40, and to the south and west by the residential suburb of Risinghurst.
The site, together with the former Nielsen House, is allocated for development under policy SP47 of the Oxford Local Plan 2036 for residential-led mixed use development including some employment use. It is noted that the office to residential conversion of Nielsen house is complete and does not form part of the proposed development; accordingly, this element is excluded from the red line of the site location plan.
The proposal, as set out in your letter, is for circa 442 apartments, a hotel, ‘innovation centre’ office space plus ancillary commercial uses. Building heights are proposed to range from three to six storeys up to a maximum AOD of 125m (excluding parapets and rooftop plant such as lift apparatus).
www.oxford.gov.uk
No part of the development is to be carried out in or near a sensitive area, as defined in Part 1 Regulation 2 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended).
Having reviewed the contents of your letter, I agree with your assessment that the development would be classed an ‘urban development project’ under paragraph 10(b) of Schedule 2 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended).
The development exceeds the 150 dwellings threshold in column 2 of the Schedule; the proposal therefore needs to be screened by the local planning authority (LPA) to determine whether significant effects on the environment are likely and hence whether an Environmental Impact Assessment is required. In screening the proposal, the selection criteria set out in Schedule 3 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended) are considered in the assessment that follows.
EIA Screening Assessment
Characteristics of development
The site was formerly part of the curtilage of a large office building and contains very little in the way of built form, consisting predominantly of hard standing and grassed, vegetated areas. The size of the built form of the proposed development would be a marked increase from the existing site conditions in terms of footprint, height and mass. However, although the development would result in an intensification of the land use through the addition of a large number of new dwellings as well as commercial uses, the uses would not be of a markedly different or incompatible nature from those in the immediate area. It is considered that the increased scale and mass is not significant for the purposes of EIA assessment and can be adequately assessed as part of the determination of a planning application.
There are no significant developments in the area that would lead to a cumulative development impact. Barton Park is a large-scale residential-led development of that is partially complete and partially under construction, lying approximately 1.5km north-west of the site. Any cumulative impacts would be limited to traffic pressure on the Green Road roundabout, which is a matter that can be satisfactorily be assessed through a Transport Assessment submitted as part of a planning application.
The development would not be likely to use natural resources which are non-renewable or in short supply, and no significant earthworks are anticipated. Site drainage is required to be sustainable through local planning policies. Similarly, the production of waste from the site, both at construction and operational stages, would not be significant, and local planning policies require the minimising of waste during construction and operation.
During both the construction and operational phase, risks relating to air quality will need to be adequately controlled. This can be appropriately achieved within the scope of a planning application through the application of appropriate planning conditions to control and mitigate risk, as informed by an Air Quality Assessment.
The impact on surrounding uses, including residential uses, from the construction phase of development can be mitigated and managed through the preparation of a Construction
Traffic Management Plan and Construction Environmental Management Plan.
The changes to vehicle movements, trip rates, parking space numbers and arrangements, and the types of vehicles using the development are not considered to be so significant as compared to the existing situation that any impacts could not be dealt with in the absence of EIA, but rather via a Transport Assessment.
There are considered to be no significant risks of major accidents or risks to human health due to the nature of the development and because the construction phase would be subject to Health and Safety regulations.
Location of development
The site has been subject to contaminated land risk assessment and remediation as part of the adjacent site’s conversion from office to residential use. This previous site investigation with updated risk assessment and validation report would be expected to form part of a planning application and further site investigation would be required following demolition of above ground structures. This is considered a sufficient mechanism to deal with land quality issues.
The site is not located on or around any designated ecological sites. The site is known to support a medium breeding population of great crested newts. Ecological assessments will need to be provided with a planning application to include great crested newts, bats and potentially reptiles. Any potential impact on species and habitats would not be significant and can be dealt with satisfactorily through the planning application process.
The site lies in Environment Agency Flood Zone 1. A flood risk assessment and drainage strategy would be required as part of a planning application to appropriately deal with surface water drainage issues and to prevent pollution to underlying ground water.
Shotover Grade I listed Registered Park and Garden lies approximately 1.5km to the south- east of the site. There is no inter-visibility between the site and this heritage asset, although urban form visible in medium and long range views could have an impact on the agricultural setting of Shotover. The site lies at the urban edge of the city of Oxford with agricultural land lying to the east and south and development on the site has the potential to be visible from a number of viewpoints including along the A40 trunk road, in long-distance views from rural footpaths and from within adjacent suburbs. The proposed heights and increase in massing on site will need careful assessment through a Landscape Visual Impact Assessment, having particular regard to night-time lighting. It is considered that the landscape impact of the development and impact on public views can be properly assessed within the scope of the planning application process through the preparation of a robust Landscape Visual Impact Assessment, which will guide the design to an acceptable height and massing and mitigate any visibility of the development.
The site has general potential for prehistoric and Roman activity. It is located 500 metres from the Roman Dorchester-Alchester Road which attracted a dispersed landscape of Roman pottery manufacturing compounds along its route, the full extent of which are not known. For a site of this scale an archaeological desk based assessment would be required, followed by a geophysical survey. There are no significant archaeological impacts likely as a result of the development.
Types and characteristics of the potential impact
As discussed above, there exists the possibility of landscape and visual impacts as a result of the development. The overall magnitude and spatial extent of the impact, the nature of the impact and the intensity and complexity of the impact are not considered to be of a scale to warrant EIA. It is considered highly likely that any visual impact can be effectively reduced via the Landscape Visual Impact Assessment used to guide the development of the design. Although the development site lies close to the boundary with South Oxfordshire District Council, there are no particular transboundary impacts likely. The Council considers that the proposed development would not give rise to any unusually complex or potentially hazardous environmental effects, which could not be addressed through the application process.
In summary, officers consider that any environmental impacts relating to the scale of development, to waste, sustainability and climate change, to ecology and biodiversity, and to any increase in traffic, emissions, air quality and noise can be adequately assessed as part of the determination of a planning application.
Having regard to Schedule 3 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended), the development proposed is not considered likely to result in significant effects on the environment.
Accordingly, in exercise of the powers conferred upon it by Regulation 6 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (as amended), the Local Planning Authority determines that the planning application proposed to be sought is not EIA development and that an EIA would not be required to accompany a planning application submitted in accordance with the details you have supplied.
Yours sincerely,
Nadia Robinson Principal Planner
For and on behalf of Adrian Arnold Head of Planning Services
Planning Statement Thornhill Park, London Road, Headington, Oxford
Roger Smith MRTPI Jon Alsop MRTPI Director Associate Director
+44 (0) 1865 26900 +44 (0) 1865 26900 [email protected] [email protected]
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