Examination of the Oxford Local Plan 2036 Matter 6: Specific Sites Cowley Investments Limited
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Examination of the Oxford Local Plan 2036 Matter 6: Specific Sites Cowley Investments Limited MAIN MATTER 6: Policy SP52: Specific Sites 1. Whether the Plan’s allocation policies are positively worded enough to encourage the delivery of beneficial developments on the sites concerned and whether they would allow sufficient flexibility in the face of future changes in circumstances 2. Whether the Plan’s approach towards the amount of development and the balance of land uses (and where relevant open space and sports provision) on the following sites is sound: 6J: Policy SP52: Oxford Stadium Question 1 1.1 The Plan’s allocation policies are not worded positively enough. An example of this is Policy SP52 that relates to the Oxford Stadium, which constrains and limits opportunities for use of the site and accordingly does not afford any flexibility should circumstances change in the future. 1.2 Policy SP52 identifies that the Stadium will reopen for greyhound and speedway racing, or failing that as a venue for community or leisure uses. However Appendix A of the HELAA Final Report of March 2019 (PSD.2) concludes that reinstatement of these uses is “non- viable” (although consultants advising the Council – presumably Five Lines – took a different view): see relevant extracts at (Appendix 9). 1.3 As set out in the response to question 2 below, Cowley Investments’ own assessment makes it clear that the stadium will never be reinstated in the manner envisaged by Policy SP52. Even if a source of funding were to be identified that would be capable of addressing the capital costs associated with reinstatement, then it is clear that the Stadium could not operate as a viable trading entity either for speedway and greyhound racing or as a venue for community / leisure uses. 1.4 With no viable alternative use for the Stadium as it currently exists, flexibility must be introduced to the Policy that would allow for complete redevelopment with housing (the obvious alternative use) provided that any new development reflects the history and former use of the site. Failing that the Policy should be deleted on the basis that it is unsound. Question 2 2.1 Cowley Investments’ response to the SDLP objected to Policy SP52 on the basis of it not being sound because it was not positively prepared, justified, effective or consistent with Savills 1 Cowley Investment Limited Examination of the Oxford Core Strategy DPD Matter 5/ 00059 national policy. The Council’s response to the second set of Inspectors Questions (OCC.2 pages 121 – 125) has re-inforced this view. 2.2 At the time of the SDLP consultation a financial appraisal that informed the ‘Oxford Stadium: Stage 1 Commercial Viability Assessment’ was not available on the grounds that it was commercially sensitive. In response to the second set of Inspectors Questions, the Council published a confidential letter between Five Lines and the Council (OCC.2 Appendix 1) via the Examination website on 30 August 2019. 2.3 The confidential letter has made available previously unseen information, detailed consideration of which by Cowley Investments clearly shows that the concept for the Oxford stadium proposed by Five Lines in their Stage 1 Assessment, and on which Policy SP52 is based, is fundamentally flawed. 2.4 There is a considerable amount of inaccuracy, inconsistency and misleading information that arises from a comparison of the Five Lines Stage 1 Assessment, the Five Lines confidential letter and the Council’s own written response to question 45 of IC.2. These are too numerous to set out within the word limit for this hearing statement. Instead this statement focuses only on two key aspects of the Council’s supporting evidence for Policy SP52. These on their own demonstrate very clearly that the Plan’s approach towards the amount of development and the balance of land uses at the Oxford Stadium site remains unsound: i. The capital costs associated with reinstating the stadium cannot be addressed through enabling development; and ii. Even if capital costs could be addressed, the uses proposed for the stadium do not represent a viable trading entity, nor would revived greyhound/speedway uses be a good neighbour. Addressing Capital Costs of Reinstating Stadium 2.5 The Five Lines letter identifies that the capital costs for reinstatement of the Stadium will be: £1.4m for land acquisition of the whole 3.37 ha site; and £1m for refurbishment of the buildings, track, general environment as well as fixtures and fittings. 2.6 In relation to land acquisition, Savills Development has provided evidence (Appendix 1) based on the Council’s ‘Economic Viability Assessment to inform the Oxford Local Plan 2036 and the Review of the Community Infrastructure Charging Schedule’ (SUP.3). This indicates that an appropriate BLV for sites in Zone 1, where the Stadium is located, would Savills 2 Cowley Investment Limited Examination of the Oxford Core Strategy DPD Matter 5/ 00059 be £2,730,000 per hectare. When multiplied by the site area (3.37 ha), the benchmark land value becomes £9,207,000. 2.7 Concerning refurbishment costs, Cowley Investments’ response to the SDLP (REP.2 / 322) identified that the capital costs associated with reinstating the Stadium to a usable condition would be in the order of £4m (exclusive of VAT, consultancy and statutory fees and inflation, intrusive and initial surveys). This figure has been arrived at by Lambert Smith Hampton (LSH), assisted by Mechanical and Electrical consultants Bennet Williams. Having visited the site and inspected all of the buildings, LSH have provided an assessment of the costs associated with the repair and reinstatement of the buildings and supporting infrastructure in a Condition Report dated December 2018 and an Addendum Condition report dated October 2019 (Appendix 2). The 2018 report identified that repair costs would be £3,813,069.12 and the 2019 report identified that repair costs would be £3,930,528.12.. Further to these repair costs would be the cost of providing improved floodlighting needed to support the broadcasting of speedway and greyhound racing events, which Cundall (Appendix 5) estimate to be at least £400,000 (excluding installation, cabaling or workmanship). Meaning that the total cost of reinstating the Stadium would be at least £4,330,528.12 compared with the unevidenced figure of £1m assumed by Five Lines. 2.8 The Five Lines letter provides a development appraisal based on residential enabling development on the Stadium’s western car park at Table 1. Based on this and some sensitivity analysis, Five Lines conclude that a scheme of 52 residential units on the 0.77 hectare western car park could generate residual profits in the region of £0.75m to £1.0m that could contribute towards the Stadium refurbishment costs. 2.9 Cowley Investments has taken advice in relation to the enabling development scheme put forward by Five Lines that demonstrates it is undeliverable and that the residual profits arrived at are unrealistic. This work has established a realistic developable area within the western car park taking account of re-provision of car parking, constraints to development caused by the operation of the stadium for greyhound and speedway racing. 2.10 The western car park currently provides parking for the entire Stadium facility and accordingly Five Lines development appraisal assumes that the 220 car parking spaces that it currently accommodates should be re-provided on site. Five Lines identify that the costs associated with re-provision of the car parking spaces would be in the order of £3.3m. Five Lines do not however address how such car parking re-provision and 52 new residential units would be accommodated within the available space. 2.11 City Planning Limited has prepared a Transport Technical Note (Appendix 3) that tests Five Lines assumptions with regard to car parking provision. With regard to car parking demand, data collected from comparable sites demonstrates that car travel dominates as the main Savills 3 Cowley Investment Limited Examination of the Oxford Core Strategy DPD Matter 5/ 00059 mode of travel to greyhound and speedway events. This is particularly true for speedway events. Using a parking ratio derived from comparable Stadiums, City Developments therefore conclude (in agreement with Five Lines) that the 220 visitor spaces currently located within the western carpark would need to be retained to ensure that the Stadium can host both greyhound and speedway events on a regular basis. 2.12 City Developments have completed a search of the surrounding area to identify off-site locations where replacement car parking might be provided. It is not possible to accommodate the required level of parking within the adjacent residential areas to the south of the Stadium. The potential locations considered included the Tesco car park to the north, the unused car park to the west of Tesco and the car park for the Lidl supermarket located on the Watlington Road (see Figure 8.1 of Highways Technical note). Only the Lidl car park is within a short walking distance. But, it only has 88 spaces, and the supermarket operates until 11pm Monday to Saturday therefore overlapping with Stadium events and ruling it out as an option. The Tesco car park and the car park to the west of it are 2km walk from the Stadium and are not therefore suitable for use by visitors as a walking distance of at least 15 minutes is too long. In addition, agreement would need to be reached with current and the future users, for example the car park to the west has planning permission for motorcycle training in the short term and in the medium term has been identified as a halt to serve the Cowley Branchline when it reopens.