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

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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

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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

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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.

2.13 The Transport Technical Note identifies that opportunities to achieve a significant mode shift towards sustainable transport options are limited at the Stadium site without significant investment. Even if such measures were put in place, City Developments conclude that demand for car parking would remain for a large proportion of visitors, given the wide catchment area and the likely cost and travel time benefits of car driving compared to other modes of travel. A further driver for on-site car parking provision is the City Council’s stated intention to implement parking controls over the whole of Oxford by 2036. Should a Controlled Parking Zone be implemented on the streets around the Stadium, adequate car parking on the site will be essential.

2.14 As there are no reasonable options for providing necessary car parking outside of the Stadium, City Developments has considered how 220 car parking spaces could be accommodated alongside enabling development on the western car park. The most appropriate solution is a decked car park at ground and first floor as illustrated by the diagram in Appendix A3 of the Transport Technical Note. The location of the new car park is appropriate given areas closer to the stadium are unlikely to be developable because of noise and floodlighting constraints. It is also the location that affords the best access to the Stadium, although proximity to the existing houses in Greyhound View may raise issues of residential amenity.

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2.15 The provision of the decked car park reduces, however, the developable area of the western carpark from 0.77 hectares to 0.39 hectares, equating to 26 residential units (at the density assumed by Five Lines) rather than the 52 relied on in the Five Lines development appraisal.

2.16 Further reductions in the developable area of the western car park will be necessary as a result of noise and lighting constraints arising from the operation of the Stadium. To establish the scale of these reductions, Bickerdike Allen Partners has completed an environmental noise assessment and Cundall has completed a lighting assessment.

2.17 The noise assessment (Appendix 4) considers the impact of the operation of the Stadium on the western car park. The assessment has been informed by noise surveys at operational greyhound and speedway tracks.

2.18 Bickerdike Allen identify a reasonable level of sound (based on BS8233:2014) as being in the range of 20 - 55 dB LAeq in external areas. They identify that this is consistent with the planning permission granted for the operation of go-kart racing from the centre of the Stadium in 1997 (97/00788/NF), where condition 3 imposed a 52 dB LAeq 15 min limit.

2.19 In terms of the impact of the operation of the Stadium on existing dwellings, the noise assessment demonstrates that noise levels at the Greyhound View development (and in associated rear gardens) would be substantial at 70 dB LAeq 1h for each of the 22 assumed speedway events (and around 60 – 65 dB LAeq 1h for each of the 150 or so assumed greyhound racing days), and that the rear flats of Holly Court would also experience noise that would exceed reasonable guidelines.

2.20 Concerning new housing that might be built on the western car park the noise assessment demonstrates that a considerable part of the western car park would be exposed to substantial areas of noise beyond reasonable guidelines, even taking account of the screening effect of the existing stadium terraces. For example, houses located close to the Stadium would be exposed to levels around 80 dB LAeq 1h for speedway events (5 – 10 dB lower for greyhound events). Towards the centre of the western car park, even taking account of the screening effect of structures noise levels will be in excess of 70 dB LAeq 1h during speedway events.

2.21 The noise assessment indicates that it may be possible to achieve reasonable acoustic conditions within new housing on the western car park, but that the mitigation measures needed to achieve this would be severe and incur additional construction costs:

 Single aspect dwellings – noise sensitive rooms could not face the stadium and gardens would need protection from noise. This is achieved for many properties in the assumed layouts considered by Savills Developments (Appendix 7), but not for all.

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 Cooling / ventilation – even with a barrier block noise levels are likely to exceed desirable noise levels inside dwellings with windows open. Mechanical ventilation and / air conditioning is therefore likely to be required.  Building envelope – high acoustic performance windows (possibly with secondary glazing) will be required and all ventilation paths would need to be acoustically treated. Roofs would need sufficient mass and / or acoustic treatment to minimise noise transfer.

2.22 The noise assessment provides further evidence that it will be impossible to accommodate the number of new homes, based on the mix relied on by Five Lines, within the western car park area. Alongside the land required to provide the decked car park, it is highly unlikely that any of the land to the east of Greyhound View will be developable. This would therefore reduce the developable area of the western car park to 0.262 hectares equating to only 18 units at the density proposed by Five Lines.

2.23 Cundall have prepared a lighting assessment to consider the requirements for floodlighting at the Stadium to support televised broadcasts of speedway and greyhound racing events (Appendix 5). The current lighting comprises of a variety of aged floodlights and fluorescents that are not in working order. Even if the lighting was operable, Cundall has advised that it would not be suitable to support the broadcast of high quality television coverage, the revenue from which Five Lines has relied on in their Profit and Loss illustration.

2.24 Cundall has therefore designed a lighting scheme that will achieve a minimum of 1400 Lux to the greyhound and speedway tracks, which would meet the lighting requirements for television broadcasting. Based on this design Cundall has modelled the impact of the replacement floodlighting, their assessment showing that the western carpark would experience exposure to unacceptable levels of light trespass. Unacceptable light trespass would also extend to significant areas of existing housing adjacent to the Stadium in Sandy Lane and the existing houses at Greyhound View. Cundall’s analysis therefore lends further support to the conclusion above that the re-use of the Stadium as envisaged in policy SP52 is not realistic or deliverable.

2.25 On the basis of the above, it can be seen that the scale and mix of enabling development which Five Lines have based their development appraisal is unachievable. Notwithstanding that this is the case, Savills Development has undertaken an independent review of the Five Lines development appraisal (Appendix 1) on the basis of their 52 unit scheme. Savills completed an initial appraisal based on Five Lines inputs under the Argus Developer software and this exercise reached a very similar residual profit level of circa £870,000. Savills then reviewed Five Lines assumptions to identify those that were not appropriate and having done so re-ran the appraisal using assumptions based on their own evidence and experience. This second exercise demonstrates that the Five Lines development of 52 units would deliver a

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negative residual profit of -£5,901,107, which is £6,772,981 less than shown by Five Lines appraisal. It would not therefore make any contribution towards the funding of capital costs associated with the reinstatement of the Stadium. This conclusion would only be worsened if allowance were to be made for developer profit, which is currently omitted from the Five Lines development appraisal.

2.26 Notwithstanding the above, to test whether a viable scheme of enabling development could be delivered on the land within the western car park available after account is taken of re- provision of car parking, noise and lighting constraints (0.262 hectares), Savills Development have also completed development appraisals for schemes of 52 and 100 flats. Flats being the only form of development compatible with the reduced site area. The 100 unit flatted scheme arises not from Five Lines (who assume 52) or from any other development analysis so far disclosed by the Council, but instead from the Council’s Cabinet Report dated 13 November 2019 (Appendix 6) that advises the Cabinet members that “some residential development is proposed as enabling development (assumed to be around 100 homes) to contribute towards the viability of the scheme.” To inform these additional development appraisals Savills Urban Design has designed schemes for 52 and 100 flats (Appendix 7). The development appraisals show a negative residual value for the 52 unit flatted scheme of -£14,539,603 and a negative residual value for the 100 units flatted scheme of -£19,996,320. These additional development appraisals clearly demonstrate that neither of the alternative schemes are viable.

2.27 As the schemes in Appendix 7 show, flatted development on the available area of the western car park would result in a significant scale of development. 7 floors of development above ground floor in the case of the 52 unit scheme and 13 floors above ground floor in the case of the 100 units scheme. Notwithstanding their unviability, enabling development provided in either form would be out of scale and not in keeping with the character of the surrounding area (and with significant outlook impacts for closest properties) making them unacceptable in any event in planning terms.

Viability of Oxford Stadium as a Trading Entity

2.28 Despite the conclusion that reinstatement of the Stadium is unviable and therefore undeliverable, John Ashworth Associates have undertaken a review of the Council’s responses to the Inspectors questions relating to Policy SP52 and have competed a review of the Profit and Loss illustration presented in the Five Lines letter to provide an understanding of whether the Stadium could operate as a viable trading entity in the event that some other source of funding for the capital costs could be secured.

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2.29 John Ashworth Associates assessment (Appendix 8) identifies that the main purpose of a revived Stadium used for greyhound racing will be to service the betting industry through broadcast of racing to betting shops. They highlight that to service this requirement, the majority of events would be held in the daytime with very few or no spectators, meaning that the assertion that the revival of the stadium is linked to visitor experience is misguided. Their review of the trading potential of the Stadium demonstrates that greyhound and speedway racing will generate insufficient revenue to make the Stadium a viable trading entity, even if the greyhound and speedway activities were to be supplemented by other sources of revenue such as conferencing. Alternative community and leisure uses would have a lesser trading potential and would also be unviable as a trading entity.

2.30 On this basis it can only be concluded that the land uses proposed by Policy SP52 are not viable and therefore are undeliverable. This reflects the view of the Council (if not Five Lines), as set out in the HELAA.

Conclusion

2.31 This statement, in combination with Cowley Investments SDLP Consultation Response clearly demonstrates that the Plan’s approach towards the amount of development and the balance of land uses proposed for the Oxford Stadium via Policy SP52 are unviable, undeliverable and accordingly unsound.

2.32 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 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.

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Review of Commercial Viability Assessment Oxford Greyhound Stadium

savills.co.uk Review of Commercial Viability Assessment Oxford Greyhound Stadium

Contents 1. Introduction & Background 1 2. Review of Five Lines Development Appraisal 2 3. Appraisal of 52 unit flatted scheme 8 4. Appraisal of 100 unit flatted scheme 11 5. Conclusion 15 Appendices 17 Appendix 1: Residual Profit Appraisal - Five Lines (52 Units) Appendix 2: Residual Profit Appraisal – Savills (52 Units) Appendix 3: Residual Profit Appraisal – Savills (52 Flats) Appendix 4: Residual Profit Appraisal – Savills (100 Flats) Appendix 5: Residual Land Value – Savills (52 Units) Appendix 6: Residual Land Value – Savills (52 Flats) Appendix 7: Residual Land Value – Savills (100 Flats)

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1. Introduction & Background

Savills has reviewed the Commercial Viability Assessment provided by Five Lines to Oxford City Council on 18 December [2017] in order to establish whether the Council’s proposed scheme is indeed viable on the site. Five Lines produced a note and a development appraisal, based on their own industry assumptions, which demonstrated that with a Compulsory Purchase Land Value of £1.4 million, a scheme of 52 units on a portion of the site that extends to 0.77 hectares would be viable and would deliver a residual profit of circa £0.9 million (£871,874).

In order to ensure that we are using the same approach employed by Five Lines to deliver their results, we have run an initial appraisal using the inputs set out in the Five Lines cover letter. Using their inputs and our software (Argus Developer), we reached a very similar residual profit level (viability gap) of circa £870,000. Having established the approach, we then re-ran the appraisal in more detail, this time using our own assumptions and evidence from third party sources. This delivered a residual profit of -£5,901,107. Copies of these appraisals are included at Appendix 1 and Appendix 2 respectively.

Further to the above, we have been informed that Emerging Policy now suggests that a smaller portion of the site would be available for provision of dwellings, as there would be a requirement to ensure provision of 220 parking spaces on site to service the retained stadium. As such, we have appraised the site on two further bases, assuming a residential development area of 0.26 ha (0.64 acres):

. a scheme of 52 flats over 7 storeys . a scheme of 100 flats over 13 storeys

Savills Urban Design team have provided high level indicative schemes of 52 and 100 flats, which we have subsequently appraised, in order to establish whether the suggested amendments to layout and increased number of units would improve the viability of the site.

The purpose of this note, therefore, is threefold; to highlight where we feel that Five Lines’ assumptions in their development appraisal are not robust and to demonstrate, with a more detailed and robust analysis, that the proposed scheme of 52 units on 0.77 ha (1.9 acres) is in fact not viable; to demonstrate that a proposed scheme comprising 52 flats on 0.26 ha (0.64 acres) is not viable; and to demonstrate that a proposed scheme comprising 100 flats would not be viable.

We would comment that, within our appraisals, we have not allowed for the following potential additional costs. We reserve the right to review our advice if further information is provided on the following: . enhanced windows to protect against noise; . enhanced ventilation systems to allow for windows not being open regularly; . undercroft parking; . opening up / strategic costs which may be necessary to unlock the site (e.g. laying any infrastructure or services and/or any upgrades to existing systems).

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2. Review of Five Lines Development Appraisal

2.1. Analysis of Assumptions

In this section we assess each of the assumptions made by Five Lines and provide comment on the inputs that we have adopted.

2.1.1. Land Cost

Five lines have assumed a land cost of £1.4 million pounds for the site based on what they would estimate to be the cost of a Compulsory Purchase Order (CPO).

Savills have consulted the Oxford City Council Economic Viability Assessment to inform the Oxford Local Plan 2036, September 2018 (the Viability Report), which suggests that an appropriate Benchmark Land Value (BLV) for sites in Zone 1, where the property is located, would be £2,730,000 per hectare. This represents a 30% premium on Existing Land Value (EUV), which is provided in the viability report as £2,100,000 per ha for Zone 1. In order to deliver the proposed scheme, an incoming developer would need to purchase the entire site and, when multiplied by the whole site area (8.37 acres), the benchmark land value becomes £9,207,000. This is the land value that we have applied to our appraisal. I am instructed that my clients do not accept that this figure necessarily reflects the true value of the Site, or what would be payable in the event of a CPO. All their rights are reserved in that respect.

We acknowledge that the proposed scheme covers only 0.77 ha (1.9 acres), and that, if the proposed scheme were to be delivered, there would be a remaining site area of 6.5 acres (2.62 ha). In order to account for this, we have added a line of revenue to reflect the hypothetical existing use value of the remaining land. The EUV applied has been taken from the Viability Report, 2018 (£2,100,000 per ha / £850,200 per acre). This delivers a return value of £5,496,314 when applied to the remaining site area, which we have assumed would be receivable at the end of the project. It is beyond the scope of this report to assess the actual EUV of the stadium/track part of the site on the assumption of a covenant restricting use to greyhound/speedway/conference use, and we have not sought to do so. To the extent such an EUV would be lower than the EUVs adopted within this report, this has the effect of potentially improving the viability outputs. For the avoidance of doubt, we confirm that this aspect of EUV does not affect the BLV adopted from the Viability Report to ascertain assumed purchase value of the land, as this reflects an EUV+ approach where the premium (or “+”) element is fundamental.

2.1.2. Housing Type Mix

We have assumed the same mix as the Five Lines appraisal which assumes the following:

Type 1b flat 2b flat 2b house 3b house 4b house Total % 10% 10% 15% 50% 15% 100% Number of dwellings 5 5 8 26 8 52

This is in line with the Oxford City Council Balance of Dwellings Study, 2008.

2.1.3. Housing Type Sizes (Coverage)

In terms of the sizes of the proposed units, we have consulted the OCC Viability Report which suggests the following sizes to be appropriate for Open Market and Affordable dwelling types:

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Type 1b flat 2b flat 2b house 3b house 4b house Total GIFA (m2) Open Market 50 70 79 99 121 GIFA (sq ft) Open Market 538 753 850 1,066 1,302 GIFA (m2) Affordable 50 67 75 84 108 GIFA (sq ft) Affordable 538 721 807 904 1,163 Total accom (sq m) 258 361 611 2,554 936 4,720 Total accom (sq ft) 2,777 3,887 6,580 27,488 10,079 50,811

In order to account for the shared spaces in any blocks of flats, we have allowed an additional 15% for the GEA which translates to the following for Open Market and Affordable dwelling types respectively:

Type 1b flat 2b flat GEA (15%) Open Market (sq m) 58 81 GEA (15%) Open Market (sq ft) 619 866 GEA (15%) Affordable (sq m) 58 77 GEA (15%) Affordable (sq ft) 619 829

2.1.4. Density

We have assumed a density in line with the density applied by Five Lines in their report (i.e. 67 dwellings per hectare), equating to 52 dwellings over the site area proposed for development which extends to 0.77 ha.

2.1.5. Tenure Mix

We have assumed the same tenure mix assumptions as set out in the Five Lines report as follows:

Type % 1b flat 2b flat 2b house 3b house 4b house Total Open Market Sale % 50% 3 2 4 13 4 26 Social Rent % 20% 1 1 2 5 1 10 Affordable Rent % 15% 1 1 1 4 1 8 Shared Ownership % 15% 1 1 1 4 1 8 Total Units 52

We note that the tenure mix does reflect 50% affordable housing; however, it does not reflect the 40% social rented provision that represents the Council’s ideal tenure. We reserve the right to review this.

2.1.6. Build Cost

We have adopted the median build costs from the BCIS data base for flats and houses, rebased to Oxford, and have added a 10% buffer to this to allow for externals. As such, the adopted build costs are £165 per sq ft for flats and £140 per sq ft for houses.

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2.1.7. Car Parking

We have adopted the same costs assumed by Five Lines for the provision of 220 parking spaces at £15,000 each, which equates to a total of £3.3 million. The location of the 220 space car park is not specified by Five Lines, and so as not to conflict with their assumed layout and mix, we have assumed it is built on a hypothetical immediately adjoining site, acquired at no cost.

2.1.8. Developer Profit

Our appraisal has been run without stipulating a level of developer profit, which is calculated by the residual appraisal we have run. We would comment, however, that normally a developer profit of 20% on GDV would be sought by developers to deliver a project such as this. 2.1.9. Preliminaries

We have not included preliminary costs within our appraisal as they are accounted for within the build costs provided by BCIS. Please note that these costs do not include “opening up” costs of unlocking the site or any infrastructure upgrades that might be required to facilitate development.

2.1.10. Professional Fees

We note that Five Lines have allowed for Professional Fees at 6% of construction costs. We would comment that this is extremely low and we would expect that professional fees would be in the order of 10% construction costs. This is what we have applied to our appraisal.

2.1.11. Legal

We note that Five Lines have applied a combined rate of 1.5% of construction costs to allow for Marketing, Agency and Legal costs. This is not how we would expect this to be calculated and we have separated these costs out and applied percentages that are more widely accepted by the industry. We have applied legal costs at 0.5% of GDV.

2.1.12. Marketing

We have applied marketing costs at 1% of GDV for open market units only.

2.1.13. Sales agency

We have applied Sales Agency costs at 1% of GDV for open market units only.

2.1.14. Contingency

The Five Lines Report allows 5% Contingency on build costs. This is widely considered an appropriate level and we have adopted the same level for contingency within our appraisal.

2.1.15. Allowance for finance costs

We note that Five Lines have allowed for finance costs of £250,000. We have applied a rate of 7% as the cost of finance which is in line with the lending rates seen in the current market. It should be noted that our appraisal assumes that the development will be 100% debt funded.

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2.1.16. Stamp Duty

We have allowed for Stamp Duty Land Tax at the rates introduced in April 2016. We note that no allowance for Stamp Duty was included within the Five Lines appraisal.

2.1.17. CIL

The Five Lines Report does not allow for any CIL on open market units. We have applied the CIL rate that is anticipated to come in 2020 to the total area of Open Market accommodation (£200 per sq m). We reserve the right to review this charge should these assumed rates not apply in the new year.

2.1.18. Environmental Policies

In line with the Viability Report (2018), we have allowed a cost of £15,000 per unit for Environmental Policies. This applies to all dwelling tenures.

2.1.19. Gross Development Value

Based on our own research of sales values in the local area, we have applied sales values to our appraisal as follows:

1b flat 2b flat 2b house 3b house 4b house Total Unit £ based on OM £220,000 £265,000 £295,000 £325,000 £360,000 £/sq ft £409 £352 £347 £305 £276 Total £567,490 £683,568 £1,141,429 £4,191,688 £1,392,930 £7,977,104 Unit £ based on SR £69,000 £78,000 £73,000 £81,000 £88,000 £/sq ft £128 £108 £90 £90 £76 Total £71,194 £80,480 £112,982 £417,879 £136,198 £818,733 Unit £ based on Aff £176,000 £212,000 £236,000 £260,000 £288,000 £/sq ft £327 £294 £292 £288 £248 Total £136,198 £164,056 £273,943 £1,006,005 £334,303 £1,914,505 Unit £ based on SO £185,000 £187,000 £213,000 £245,000 £372,000 £/sq ft £344 £259 £264 £271 £320 Total £143,162 £144,710 £247,245 £947,966 £431,808 £1,914,892 Total GDV £12,625,234

It should be noted that the sales values applied to the Social Rented (SR) and Shared Ownership (SO) units have been taken from the Viability Report (2018). Open Market (OM) values are reflective of recent transaction of units in the more immediate area and Affordable (AFF) units are reflective of 80% of the OM units.

We would comment that the sales values seen in this particular part of Oxford fall well below those seen in other districts, particularly those that are nearer the city centre or located near universities. There is no directly comparable information available to support sales values as no schemes such as this have come forward in recent years.

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2.2. Results

As stated in the introduction, when adjustments are made to the appraisal to reflect what we would believe to be realistic assumptions based on our experience in the market, independent research and assumptions stated within documents published on the Oxford City Council website, the results are considerably different to those produced by the Five Lines appraisal. The Residual Profit (Viability Gap) becomes -£5,901,107, which is £6,772,981 less than the figure delivered by Five Lines.

We set out in the below table a summary of the differences between the two appraisals, marking in bold the cost differences of each item that exceed £100,000.

Five Lines Savills Difference Income £ £ £ Gross development value 14,087,165 12,625,234 -1,461,931 Grant funding 0 0 Other 0 5,496,314 Total income 14,087,165 18,121,548 4,034,383 Costs £ £ £ Land (i.e., CPO cost) -1,400,000 -9,207,000 -7,807,000 Acquisition Costs (SDLT / Legal) 0 -495,885 -495,885 Build costs -6,638,788 -7,038,445 -399,657 Abnormals and infrastructure (re-provision of 220 car -3,300,000 -3,300,000 0 parking spaces) Preliminaries -796,655 0 0 Professional Fees -398,327 -703,844 -305,517 Marketing/Legal/Agency Fees -99,582 -360,076 -260,494 Contingency -331,939 -351,922 -19,983 Target development profit 0 0 0 Allowance for finance costs -250,000 -1,304,168 -1,054,168 CIL 0 -481,315 -481,315 Environmental Policies 0 -780,000 -780,000 Total costs -13,215,291 -24,022,655 -10,807,364 Residual profit / (viability gap) 871,874 -5,901,107 -6,772,981

The largest differences can be seen in the following:

2.2.1. GDV

A difference of £1,461,931 which is largely due to the values attributed to the three types of affordable housing, where values have been taken from the Viability Report (2018);

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2.2.2. Cost of Land

A difference of £7,807,000, where Savills have adopted the benchmark land value for Zone 1 as per the Viability Report (2018) and applied it to the area of the whole site. It should be noted, however, that we have added value back into the appraisal to account for the land not used for residential development, which is realised at the end of the project. This has been calculated using the relevant EUV value in the Viability Report (2018) applied to remaining site area, which results in a receipt of £5,496,314;

2.2.3. Acquisition costs

These have not been allowed for in the Five Lines appraisal, but we would typically expect to see Stamp Duty costs and legal fees of 0.5% on acquisition, which amount to £495,885;

2.2.4. Build Costs

A difference of £399,657 can be attributed to a rise in build costs generally; however, we have also been more thorough in our approach, considering build costs for flats and houses separately. Furthermore, we have taken guidance from the Viability Report on appropriate unit sizes and have also made an allowance for common spaces in flatted units which add costs but do not command additional value;

2.2.5. Professional Fees

A difference of £305,517 can be explained by the additional 4% allowed for within our appraisal. As previously mentioned, this is a common allowance made for professional fees and we would say that 6% is very light and would not be sufficient for most developments;

2.2.6. Marketing/Legal/Agency Fees

A difference of £139,982 can be explained by the allowances that we have made, separating legal fees (0.5% GDV), marketing costs (1% GDV) and Agency Fees (1% GDV) which total 2.5% of GDV as opposed to the 1.5% of costs allowed for by Five Lines. As previously explained, our methodology is widely accepted in development appraisals and we would not typically see these fees combined at the level suggested by Five Lines, then calculated on costs;

2.2.7. Finance Costs

A difference of £142,154 can be explained by the cost of borrowing over time. As mentioned, we have assumed that the development would be 100% debt funded at a rate of 7%, which is reflective of lending rates in the current market;

2.2.8. CIL

No allowance has been made for CIL in the Five Lines appraisal; however, the current CIL rates for residential dwellings are £144.19 per sq m of development. We are informed that CIL is expected to rise to £200 per sq m, which would equate to £481,315 for the open market provision. As mentioned, should this amount vary when CIL rates are revised, we reserve the right to review our appraisal;

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2.2.9. Environmental Policies

No allowance has been made for Environmental Policies within the Five Lines appraisal; however, we note that in the Viability Report (2018) a suggested allowance of £15,000 per dwelling is made to reflect environmental targets. We have applied this to each unit which delivers an additional cost of £780,000.

3. Appraisal of 52 unit flatted scheme Further to the above, we have appraised the site based on a scheme of 52 flats built on a parcel extending to 0.26ha (0.64 acres), in accordance with suggested emerging policy. This exercise has been undertaken to establish whether a proposed scheme of 52 flats, provided over 7 storeys, alongside the retained existing stadium, would be a viable option. Having run the appraisal, we arrived at a Residual Profit (Viability Gap) of -£14,539,603. This result can be explained by the following assumptions which were applied to our appraisal.

3.1. Assumptions

In this section we outline each of the assumptions made, providing comment on the inputs that we have adopted.

3.1.1. Land Cost

As with our first appraisal, we have applied a BLV of £2,730,000 per hectare to the site area, delivering an initial purchase price of £9,207,000.

The hypothetical existing use value of the remaining land (3.13 ha / 7.73 acres), receivable at the end of the project, is £6,567,314. This is larger than the figure seen in the previous appraisal for 52 units, as it reflects a larger area of land that has not been developed for the proposed residential scheme.

3.1.2. Housing Type Mix

We have assumed the following mix, taken from the proposed layout from the Savills Urban Design team:

Type 1b flat 2b flat 3b flat 4b flat Total % 33% 38% 23% 6% 100% Number of dwellings 17 20 12 3 52

We acknowledge that this deviates slightly from the Oxford City Council Balance of Dwellings Study, 2008, but as it is a higher density scheme (200 dwellings per hectare) we feel that this is a fair balance.

3.1.3. Housing Type Sizes (Coverage)

We have been given approximate areas for the proposed units; however, as we are unable to determine at this stage which would be allocated as open market and which would be allocated for various affordable tenures, we have considered the average sizes of each unit type within our appraisal so as to treat them as tenure blind. The average sizes of each unit type are set out in the below table:

Cowley Investments Ltd November 2019 8

Type 1b flat 2b flat 3b flat 4b flat Total GIFA (m2) 52.5 77.7 102.5 134 GIFA (sq ft) 565 836 1,103 1,442 Total accom (sq m) 901 1,535 1,226 418 4,080 Total accom (sq ft) 9,697 16,526 13,195 4,500 43,919

We were also provided with the Gross Floor Area of each floor plate (813 sq m / 8,751 sq ft), with which we were able to calculate the average gross area of each unit type, which we set out in the below table:

Type 1b flat 2b flat 3b flat 4b flat Total GFA (sq m) 73 108 143 187 GFA (sq ft) 789 1167 1540 2013 Total GFA (sq m) 1,257 2,143 1,711 583 5,694 Total GFA (sq ft) 13,533 23,064 18,416 6,280 61,294

It should be noted that the gross area takes into account all shared spaces, corridors, storage and undercroft parking for which we have not, at this stage, made an additional allowance.

3.1.4. Density

As mentioned above, the density of the proposed scheme is 52 units per 0.26 ha (0.64 acres), which results in 200 dwellings per ha (81 dwellings per acre).

3.1.5. Tenure Mix

We have assumed the a policy compliant tenure mix as follows:

Type % 1b flat 2b flat 3b flat 4b flat Total Open Market Sale % 50% 8 10 6 1 25 Social Rent % 40% 7 8 5 2 22 Affordable Rent % 5% 1 1 1 0 3 Shared Ownership % 5% 1 1 0 0 2 Total Units 17 20 12 3 52

3.1.6. Build Cost

We have adopted the median build costs from the BCIS data base for flats of 6+ storeys (as the units will be provided over 7 storeys), rebased to Oxford, and have added a 10% buffer to this to allow for externals. As such, the adopted build costs are £199 per sq ft.

3.1.7. Car Parking

We have adopted the same costs assumed by Five Lines for the provision of 220 parking spaces at £15,000 each, which equates to a total of £3.3 million.

Cowley Investments Ltd November 2019 9

3.1.8. Developer Profit

3.1.9. Preliminaries

We have assumed the same as in 2.1.9 (preliminaries included in Build Cost).

3.1.10. Professional Fees

We have assumed 10% (same as 2.1.10).

3.1.11. Legal

We have applied legal costs at 0.5% of GDV.

3.1.12. Marketing

We have applied marketing costs at 1% of GDV for open market units only.

3.1.13. Sales agency

We have applied Sales Agency costs at 1% of GDV for open market units only.

3.1.14. Contingency

We have applied 5% to build cost to allow for contingency.

3.1.15. Allowance for finance costs

We have applied a rate of 7% as the cost of finance and have assumed that the development will be 100% debt funded.

3.1.16. Stamp Duty

We have allowed for Stamp Duty Land Tax at the rates introduced in April 2016.

3.1.17. CIL

We have applied CIL at £200 per sq m to the total area of Open Market accommodation. We reserve the right to review this should these assumed rates not apply.

3.1.18. Environmental Policies

We have allowed £15,000 per unit for Environmental Policies. This applies to all dwelling tenures.

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3.1.19. Gross Development Value

Based on our own research of sales values in the local area, we have applied sales values to our appraisal as follows:

1b flat 2b flat 2b house 3b house Total Unit £ based on OM £230,000 £285,000 £325,000 £375,000 £/sq ft £407 £341 £295 £260 Total £1,840,000 £2,850,000 £1,950,000 £375,000 £7,015,000 Unit £ based on SR £69,000 £78,000 £81,000 £90,000 £/sq ft £122 £93 £73 £62 Total £483,000 £624,000 £405,000 £180,000 £1,692,000 Unit £ based on Aff £184,000 £228,000 £260,000 £300,000 £/sq ft £326 £273 £236 £208 Total £184,000 £228,000 £260,000 £0 £672,000 Unit £ based on SO £185,000 £187,000 £211,000 £220,000 £/sq ft £327 £224 £191 £153 Total £185,000 £187,000 £0 £0 £372,000 Total GDV £9,751,000

It should be noted that the sales values applied to the Social Rented (SR) and Shared Ownership (SO) units have been taken from the Viability Report (2018), except for 4 bed flats, where we have made an assumption on appropriate values in line with those given. Open Market (OM) values are reflective of recent transaction of units in the more immediate area and Affordable (AFF) units are reflective of 80% of the OM units.

3.2. Results

The appraisal delivered a Residual Profit (Viability Gap) of -£14,539,603 which equates to -89.10% profit on GDV, if this scheme were to be delivered. A summary of our appraisal is included at Appendix 3 . This clearly demonstrates that the proposed scheme is unviable.

4. Appraisal of 100 unit flatted scheme

In addition, we have appraised the site based on a scheme of 100 flats built on the same parcel extending to 0.26ha (0.64 acres), in accordance with suggested emerging policy. This exercise has been undertaken to establish whether a proposed scheme of 100 flats, built over 13 storeys, alongside the retained existing stadium, would be a viable option. Having run the appraisal, we arrived at a Residual Profit (Viability Gap) of -£19,996,320. This result can be explained by the following assumptions which were applied to our appraisal.

4.1. Assumptions

In this section we outline each of the assumptions made, providing comment on the inputs that we have adopted.

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4.1.1. Land Cost

As with our previous appraisals, we have applied a BLV of £2,730,000 per hectare to the site area, delivering an initial purchase price of £9,207,000.

The hypothetical existing use value of the remaining land (3.13 ha / 7.73 acres), receivable at the end of the project, is £6,567,314.

4.1.2. Housing Type Mix

We have assumed the following mix, taken from the proposed layout from the Savills Urban Design team:

Type 1b flat 2b flat 3b flat 4b flat Total % 32% 38% 24% 6% 100% Number of dwellings 32 38 24 6 100

We acknowledge that this deviates slightly from the Oxford City Council Balance of Dwellings Study, 2008, but as it is a higher density scheme (385 dwellings per hectare) we feel that this is a fair balance.

4.1.3. Housing Type Sizes (Coverage)

We have been given approximate areas for the proposed units; however, as above, we are unable to determine which would be allocated for each tenure. We have therefore considered the average sizes of each unit type within our appraisal so as to treat them as tenure blind. The average sizes of each unit type are set out in the below table:

Type 1b flat 2b flat 3b flat 4b flat Total GIFA (m2) 52.5 77.7 102.5 134 GIFA (sq ft) 565 836 1,103 1,442 Total accom (sq m) 1,733 2,953 2,358 804 7,847 Total accom (sq ft) 18,648 31,781 25,376 8,654 84,460

We have again used the gross area of the combined floor plates (813 sq m / 8,751 sq ft per floor), with which we were able to calculate the average gross area of each unit type, which we set out in the below table:

Type 1b flat 2b flat 3b flat 4b flat Total GFA (sq m) 73 108 143 187 GFA (sq ft) 757 1121 1478 1933 Total GFA (sq m) 2,418 4,121 3,290 1,122 10,951 Total GFA (sq ft) 24,989 42,587 34,004 11,597 113,176

It should be noted that the gross area takes into account all shared spaces, corridors, storage and undercroft parking for which we have not, at this stage, made an additional allowance.

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4.1.4. Density

As mentioned above, the density of the proposed scheme is 100 units per 0.26 ha (0.64 acres), which results in 385 dwellings per ha (156 dwellings per acre).

4.1.5. Tenure Mix

We have assumed the a policy compliant tenure mix as follows:

Type % 1b flat 2b flat 3b flat 4b flat Total Open Market Sale % 50% 16 19 11 3 49 Social Rent % 40% 13 15 9 2 39 Affordable Rent % 5% 2 2 2 1 7 Shared Ownership % 5% 1 2 2 0 5 Total Units 32 38 24 6 100

4.1.6. Build Cost

We have adopted the median build costs from the BCIS data base for flats of 6+ storeys (as the units will be provided over 13 storeys), rebased to Oxford, and have added a 10% buffer to this to allow for externals. As such, the adopted build costs are £199 per sq ft.

We would comment that 13 storeys is a significant height and would likely command a higher build cost. We reserve the right to review this in due course.

4.1.7. Car Parking

We have adopted the same costs assumed by Five Lines for the provision of 220 parking spaces at £15,000 each, which equates to a total of £3.3 million.

4.1.8. Developer Profit

4.1.9. Preliminaries

We have assumed the same as in 2.1.9 (preliminaries included in Build Cost).

4.1.10. Professional Fees

We have assumed 10% (same as 2.1.10).

4.1.11. Legal

We have applied legal costs at 0.5% of GDV.

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4.1.12. Marketing

We have applied marketing costs at 1% of GDV for open market units only.

4.1.13. Sales agency

We have applied Sales Agency costs at 1% of GDV for open market units only.

4.1.14. Contingency

We have applied 5% to build cost to allow for contingency.

4.1.15. Allowance for finance costs

We have applied a rate of 7% as the cost of finance and have assumed that the development will be 100% debt funded.

4.1.16. Stamp Duty

We have allowed for Stamp Duty Land Tax at the rates introduced in April 2016.

4.1.17. CIL

We have applied CIL at £200 per sq m to the total area of Open Market accommodation. We reserve the right to review this should these assumed rates not apply.

4.1.18. Environmental Policies

We have allowed £15,000 per unit for Environmental Policies. This applies to all dwelling tenures.

4.1.19. Gross Development Value

Based on our own research of sales values in the local area, we have applied sales values to our appraisal as follows:

Cowley Investments Ltd November 2019 14

1b flat 2b flat 2b house 3b house Total Unit £ based on OM £230,000 £285,000 £325,000 £375,000 £/sq ft £407 £341 £295 £260 Total £3,680,000 £5,415,000 £3,575,000 £1,125,000 £13,795,000 Unit £ based on SR £69,000 £78,000 £81,000 £90,000 £/sq ft £122 £93 £73 £62 Total £897,000 £1,170,000 £729,000 £180,000 £2,976,000 Unit £ based on Aff £184,000 £228,000 £260,000 £300,000 £/sq ft £326 £273 £236 £208 Total £368,000 £456,000 £520,000 £300,000 £1,644,000 Unit £ based on SO £185,000 £187,000 £211,000 £220,000 £/sq ft £327 £224 £191 £153 Total £185,000 £374,000 £422,000 £0 £981,000 Total GDV £19,396,000

As with the appraisal for 52 flats, the sales values applied to the Social Rented (SR) and Shared Ownership (SO) units have been taken from the Viability Report (2018), except for 4 bed flats, where we have made an assumption on appropriate values in line with those given. Open Market (OM) values are reflective of recent transaction of units in the more immediate area and Affordable (AFF) units are reflective of 80% of the OM units.

4.2. Results

The appraisal delivered a Residual Profit (Viability Gap) of -£19,996,320 which equates to -77.02% profit on GDV, if this scheme were to be delivered. A summary of our appraisal is included at Appendix 4. This clearly demonstrates that the proposed scheme is unviable.

5. Conclusion

The above evidence, appraisals and results clearly demonstrate that there are significant allowances that have not been made within the Five Lines appraisal that we would normally expect to see should an incoming developer or housebuilder seek to deliver the proposed scheme. When these allowances are factored into the appraisal, it becomes apparent that the development proposed by Five Lines is not viable, delivering a negative residual profit of -32.56% GDV, which falls well below the 20% GDV profit level that would typically be sought by a developer.

To further support our findings, we have altered our appraisal and input a developer profit level of 20% GDV to deliver a land value for the site. The target profit level at 20% GDV is £3,624,310, and when this is allowed for within the appraisal, a residual land value of -£1,164,564 is delivered. A copy of this appraisal is included at Appendix 5. It is clear that, at this level, a land owner would not be incentivised to release the land for residential development, as the residual value falls far below the benchmark land value of £9,207,000. The landowner would instead either most likely retain the land for release at a future date, or dispose of the land at its existing use value.

Cowley Investments Ltd November 2019 15

When appraising the site based on a scheme of 52 flats delivered on 0.26 ha (0.64 acres) of the site, we arrive at a negative profit of -89.10%. Again, to support our calculations, we have reversed the appraisal by inputting a 20% profit on GDV target into the appraisal (£3,263,662), to deliver the residual land value. In this scenario, the residual land value generated is -£6,318,609. The appraisal summary is included at Appendix 6 . At this level a landowner would not be incentivised to sell the land for residential development.

Finally, when appraising the site based on a scheme of 100 flats delivered on 0.26 ha (0.64 acres) of the site, we arrive at a negative profit of -77.02%. When we reversed the appraisal and input a 20% profit on GDV target into the appraisal (£5,192,658), the residual land value generated is -£12,239,869. The appraisal summary is included at Appendix 7. A landowner would clearly not be incentivised to sell the land for residential development at this level.

In summary, we would not consider any of the above proposed schemes to be viable as neither a developer, nor a landowner would be incentivised to bring the scheme forward.

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Appendices

Cowley Investments Ltd November 2019 17

Appendix 1 : Residual Profit Appraisal - Five Lines (52 Units)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

REVENUE Sales Valuation Units ft² Rate ft² Unit Price Gross Sales 1b flat OM 1 1,388 418.15 580,388 580,388 2b flat OM 1 1,860 360.58 670,670 670,670 2b house OM 1 3,124 384.01 1,199,648 1,199,648 3b house OM 1 11,800 371.62 4,385,150 4,385,150 4b house OM 1 3,957 386.24 1,528,354 1,528,354 1b flat SR 1 500 176.44 88,219 88,219 2b flat SR 1 670 159.39 106,791 106,791 2b house SR 1 1,125 154.77 174,116 174,116 3b house SR 1 4,248 156.30 663,963 663,963 4b house SR 1 1,424 166.29 236,798 236,798 1b flat Aff 1 444 362.52 160,961 160,961 2b flat Aff 1 595 305.21 181,597 181,597 2b house Aff 1 1,000 303.35 303,349 303,349 3b house Aff 1 3,776 322.44 1,217,524 1,217,524 4b house Aff 1 1,266 332.52 420,974 420,974 1b flat SO 1 444 334.64 148,579 148,579 2b flat SO 1 595 291.33 173,342 173,342 2b house SO 1 1,000 309.54 309,540 309,540 3b house SO 1 3,776 300.58 1,134,980 1,134,980 4b house SO 1 1,266 317.85 402,402 402,402 Totals 20 44,258 14,087,345

NET REALISATION 14,087,345

OUTLAY

ACQUISITION COSTS Fixed Price 1,400,000 1,400,000 CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 1,388 ft² 150.00 pf² 208,200 2b flat OM 1,860 ft² 150.00 pf² 279,000 2b house OM 3,124 ft² 150.00 pf² 468,600 3b house OM 11,800 ft² 150.00 pf² 1,770,000 4b house OM 3,957 ft² 150.00 pf² 593,550 1b flat SR 500 ft² 150.00 pf² 75,000 2b flat SR 670 ft² 150.00 pf² 100,500 2b house SR 1,125 ft² 150.00 pf² 168,750 3b house SR 4,248 ft² 150.00 pf² 637,200 4b house SR 1,424 ft² 150.00 pf² 213,600 1b flat Aff 444 ft² 150.00 pf² 66,600 2b flat Aff 595 ft² 150.00 pf² 89,250 2b house Aff 1,000 ft² 150.00 pf² 150,000 3b house Aff 3,776 ft² 150.00 pf² 566,400 4b house Aff 1,266 ft² 150.00 pf² 189,900 1b flat SO 444 ft² 150.00 pf² 66,600 2b flat SO 595 ft² 150.00 pf² 89,250 2b house SO 1,000 ft² 150.00 pf² 150,000 3b house SO 3,776 ft² 150.00 pf² 566,400 4b house SO 1,266 ft² 150.00 pf² 189,900 Totals 44,258 ft² 6,638,700 6,638,700

Contingency 5.00% 331,935 331,935 Other Construction Preliminaries 12.00% 398,322 Parking 3,300,000 Agent/Legal/Marketing 1.50% 49,790

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Five Lines - Multi Phase.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS Preliminaries 12.00% 143,406 Agent/Legal/Marketing 1.50% 17,926 Preliminaries 12.00% 127,458 Agent/Legal/Marketing 1.50% 15,932 Preliminaries 12.00% 127,458 Agent/Legal/Marketing 1.50% 15,932 4,196,224

PROFESSIONAL FEES Professional Fees 6.00% 398,322 398,322 FINANCE Debit Rate 10.50% Credit Rate 0.00% (Nominal) Total Finance Cost 251,754

TOTAL COSTS 13,216,935

PROFIT 870,410

Performance Measures Profit on Cost% 6.59% Profit on GDV% 6.18% Profit on NDV% 6.18%

IRR 30.93%

Profit Erosion (finance rate 10.500%) 0 yrs 7 mths

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Five Lines - Multi Phase.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019

Appendix 2 : Residual Profit Appraisal – Savills (52 Units)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

REVENUE Sales Valuation Units ft² Rate ft² Unit Price Gross Sales 1b flat OM 1 1,388 408.85 567,490 567,490 2b flat OM 1 1,944 351.63 683,568 683,568 2b house OM 1 3,290 346.94 1,141,429 1,141,429 3b house OM 1 13,744 304.98 4,191,688 4,191,688 4b house OM 1 5,039 276.43 1,392,930 1,392,930 Remaining Land Value 1 0 0.00 5,496,314 5,496,314 1b flat SR 1 555 128.28 71,194 71,194 2b flat SR 1 744 108.17 80,480 80,480 2b house SR 1 1,249 90.46 112,982 112,982 3b house SR 1 4,665 89.58 417,879 417,879 4b house SR 1 1,799 75.71 136,198 136,198 1b flat Aff 1 416 327.40 136,198 136,198 2b flat Aff 1 588 279.01 164,056 164,056 2b house Aff 1 937 292.36 273,943 273,943 3b house Aff 1 3,498 287.59 1,006,005 1,006,005 4b house Aff 1 1,349 247.82 334,303 334,303 1b flat SO 1 416 344.14 143,162 143,162 2b flat SO 1 558 259.34 144,710 144,710 2b house SO 1 937 263.87 247,245 247,245 3b house SO 1 3,498 271.00 947,966 947,966 4b house SO 1 1,349 320.09 431,808 431,808 Totals 21 47,963 18,121,548

NET REALISATION 18,121,548

OUTLAY

ACQUISITION COSTS Fixed Price 9,207,000 Stamp Duty 449,850 Legal Fee 0.50% 46,035 9,702,885 CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 1,597 ft² 165.00 pf² 263,505 2b flat OM 2,235 ft² 165.00 pf² 368,775 2b house OM 3,290 ft² 140.00 pf² 460,600 3b house OM 13,744 ft² 140.00 pf² 1,924,160 4b house OM 5,039 ft² 140.00 pf² 705,460 1b flat SR 639 ft² 165.00 pf² 105,435 2b flat SR 856 ft² 165.00 pf² 141,240 2b house SR 1,249 ft² 140.00 pf² 174,860 3b house SR 4,665 ft² 140.00 pf² 653,100 4b house SR 1,799 ft² 140.00 pf² 251,860 1b flat Aff 479 ft² 165.00 pf² 79,035 2b flat Aff 642 ft² 165.00 pf² 105,930 2b house Aff 937 ft² 140.00 pf² 131,180 3b house Aff 3,498 ft² 140.00 pf² 489,720 4b house Aff 1,349 ft² 140.00 pf² 188,860 1b flat SO 479 ft² 165.00 pf² 79,035 2b flat SO 642 ft² 165.00 pf² 105,930 2b house SO 937 ft² 140.00 pf² 131,180 3b house SO 3,498 ft² 140.00 pf² 489,720 4b house SO 1,349 ft² 140.00 pf² 188,860 Totals 48,923 ft² 7,038,445 7,038,445

Contingency 5.00% 351,922 351,922 Other Construction

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS Parking 3,300,000 CIL 25,905 ft² 18.58 pf² 481,315 Environmental Policies 390,000 Environmental Policies 150,000 Environmental Policies 120,000 Environmental Policies 120,000 4,561,315

PROFESSIONAL FEES Professional Fees 10.00% 703,844 703,844 DISPOSAL FEES Sales Agent Fee & Marketing 2.00% 269,468 Sales Legal Fee 0.50% 90,608 360,076 FINANCE Debit Rate 7.00% Credit Rate 0.00% (Nominal) Total Finance Cost 1,304,168

TOTAL COSTS 24,022,656

PROFIT (5,901,108)

Performance Measures Profit on Cost% (24.56)% Profit on GDV% (32.56)% Profit on NDV% (32.56)%

IRR (25.94)%

Profit Erosion (finance rate 7.000%) N/A

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019

Appendix 3 : Residual Profit Appraisal – Savills (52 Flats)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

REVENUE Sales Valuation Units ft² Rate ft² Unit Price Gross Sales 1b flat OM 8 4,520 407.08 230,000 1,840,000 2b flat OM 10 8,360 340.91 285,000 2,850,000 3b flat OM 6 6,618 294.65 325,000 1,950,000 4b flat OM 1 1,442 260.06 375,000 375,000 Remaining Land Value 1 0 0.00 6,567,314 6,567,314 1b flat SR 7 3,955 122.12 69,000 483,000 2b flat SR 8 6,688 93.30 78,000 624,000 3b flat SR 5 5,515 73.44 81,000 405,000 4b flat SR 2 2,884 62.41 90,000 180,000 1b flat Aff 1 565 325.66 184,000 184,000 2b flat Aff 1 836 272.73 228,000 228,000 3b flat Aff 1 1,103 235.72 260,000 260,000 1b flat SO 1 565 327.43 185,000 185,000 2b flat SO 1 836 223.68 187,000 187,000 Totals 53 43,887 16,318,314

NET REALISATION 16,318,314

OUTLAY

ACQUISITION COSTS Fixed Price 9,207,000 Stamp Duty 449,850 Legal Fee 0.50% 46,035 9,702,885 CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 6,312 ft² 199.00 pf² 1,256,088 2b flat OM 11,670 ft² 199.00 pf² 2,322,330 3b flat OM 9,240 ft² 199.00 pf² 1,838,760 4b flat OM 2,013 ft² 199.00 pf² 400,587 1b flat SR 5,523 ft² 199.00 pf² 1,099,077 2b flat SR 9,336 ft² 199.00 pf² 1,857,864 3b flat SR 7,700 ft² 199.00 pf² 1,532,300 4b flat SR 4,026 ft² 199.00 pf² 801,174 1b flat Aff 789 ft² 199.00 pf² 157,011 2b flat Aff 1,167 ft² 199.00 pf² 232,233 3b flat Aff 1,540 ft² 199.00 pf² 306,460 1b flat SO 789 ft² 199.00 pf² 157,011 2b flat SO 1,167 ft² 199.00 pf² 232,233 Totals 61,272 ft² 12,193,128 12,193,128

Contingency 5.00% 609,656 609,656 Other Construction Parking 3,300,000 CIL 29,235 ft² 18.58 pf² 543,186 Environmental Policies 25 un 15,000.00 /un 375,000 Environmental Policies 22 un 15,000.00 /un 330,000 Environmental Policies 3 un 15,000.00 /un 45,000 Environmental Policies 2 un 15,000.00 /un 30,000 4,623,186

PROFESSIONAL FEES Professional Fees 10.00% 1,219,313 1,219,313 DISPOSAL FEES Sales Agent Fee & Marketing 2.00% 271,646 Sales Legal Fee 0.50% 81,592

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2 - 52 Flats.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS 353,238 FINANCE Debit Rate 7.00% Credit Rate 0.00% (Nominal) Total Finance Cost 2,156,511

TOTAL COSTS 30,857,917

PROFIT (14,539,603)

Performance Measures Profit on Cost% (47.12)% Profit on GDV% (89.10)% Profit on NDV% (89.10)%

IRR (43.68)%

Profit Erosion (finance rate 7.000%) N/A

Appendix 4: Residual Profit Appraisal – Savills (100 Flats)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

REVENUE Sales Valuation Units ft² Rate ft² Unit Price Gross Sales 1b flat OM 16 9,040 407.08 230,000 3,680,000 2b flat OM 19 15,884 340.91 285,000 5,415,000 3b flat OM 11 12,133 294.65 325,000 3,575,000 4b flat OM 3 4,326 260.06 375,000 1,125,000 Remaining Land Value 1 0 0.00 6,567,314 6,567,314 1b flat SR 13 7,345 122.12 69,000 897,000 2b flat SR 15 12,540 93.30 78,000 1,170,000 3b flat SR 9 9,927 73.44 81,000 729,000 4b flat SR 2 2,884 62.41 90,000 180,000 1b flat Aff 2 1,130 325.66 184,000 368,000 2b flat Aff 2 1,672 272.73 228,000 456,000 3b flat Aff 2 2,206 235.72 260,000 520,000 4b flat Aff 1 1,442 208.04 300,000 300,000 1b flat SO 1 565 327.43 185,000 185,000 2b flat SO 2 1,672 223.68 187,000 374,000 3b flat SO 2 2,206 191.30 211,000 422,000 Totals 101 84,972 25,963,314

NET REALISATION 25,963,314

OUTLAY

ACQUISITION COSTS Fixed Price 9,207,000 Stamp Duty 449,850 Legal Fee 0.50% 46,035 9,702,885 CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 12,112 ft² 199.00 pf² 2,410,288 2b flat OM 21,299 ft² 199.00 pf² 4,238,501 3b flat OM 16,258 ft² 199.00 pf² 3,235,342 4b flat OM 5,799 ft² 199.00 pf² 1,154,001 1b flat SR 9,841 ft² 199.00 pf² 1,958,359 2b flat SR 16,815 ft² 199.00 pf² 3,346,185 3b flat SR 13,302 ft² 199.00 pf² 2,647,098 4b flat SR 3,866 ft² 199.00 pf² 769,334 1b flat Aff 1,514 ft² 199.00 pf² 301,286 2b flat Aff 2,242 ft² 199.00 pf² 446,158 3b flat Aff 2,956 ft² 199.00 pf² 588,244 4b flat Aff 1,933 ft² 199.00 pf² 384,667 1b flat SO 757 ft² 199.00 pf² 150,643 2b flat SO 2,242 ft² 199.00 pf² 446,158 3b flat SO 2,956 ft² 199.00 pf² 588,244 Totals 113,892 ft² 22,664,508 22,664,508

Contingency 5.00% 1,133,225 1,133,225 Other Construction Parking 3,300,000 CIL 55,468 ft² 18.58 pf² 1,030,595 Environmental Policies 49 un 15,000.00 /un 735,000 Environmental Policies 39 un 15,000.00 /un 585,000 Environmental Policies 7 un 15,000.00 /un 105,000 Environmental Policies 5 un 15,000.00 /un 75,000 5,830,595

PROFESSIONAL FEES Professional Fees 10.00% 2,266,451

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2 - 100 Flats.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS 2,266,451 DISPOSAL FEES Sales Agent Fee & Marketing 2.00% 407,246 Sales Legal Fee 0.50% 129,817 537,063 FINANCE Debit Rate 7.00% Credit Rate 0.00% (Nominal) Total Finance Cost 3,824,907

TOTAL COSTS 45,959,635

PROFIT (19,996,321)

Performance Measures Profit on Cost% (43.51)% Profit on GDV% (77.02)% Profit on NDV% (77.02)%

IRR (36.76)%

Profit Erosion (finance rate 7.000%) N/A

Appendix 5: Residual Land Value – Savills (52 Units)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

NET REALISATION 18,121,548

OUTLAY

ACQUISITION COSTS Residualised Price 1,164,564 Stamp Duty 47,728 Legal Fee 0.50% 5,823 1,218,115 CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 1,597 ft² 165.00 pf² 263,505 2b flat OM 2,235 ft² 165.00 pf² 368,775 2b house OM 3,290 ft² 140.00 pf² 460,600 3b house OM 13,744 ft² 140.00 pf² 1,924,160 4b house OM 5,039 ft² 140.00 pf² 705,460 1b flat SR 639 ft² 165.00 pf² 105,435 2b flat SR 856 ft² 165.00 pf² 141,240 2b house SR 1,249 ft² 140.00 pf² 174,860 3b house SR 4,665 ft² 140.00 pf² 653,100 4b house SR 1,799 ft² 140.00 pf² 251,860 1b flat Aff 479 ft² 165.00 pf² 79,035 2b flat Aff 642 ft² 165.00 pf² 105,930 2b house Aff 937 ft² 140.00 pf² 131,180 3b house Aff 3,498 ft² 140.00 pf² 489,720 4b house Aff 1,349 ft² 140.00 pf² 188,860 1b flat SO 479 ft² 165.00 pf² 79,035 2b flat SO 642 ft² 165.00 pf² 105,930 2b house SO 937 ft² 140.00 pf² 131,180 3b house SO 3,498 ft² 140.00 pf² 489,720 4b house SO 1,349 ft² 140.00 pf² 188,860 Totals 48,923 ft² 7,038,445 7,038,445

Contingency 5.00% 351,922 351,922 Other Construction

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2 - RLV.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS Parking 3,300,000 CIL 25,905 ft² 18.58 pf² 481,315 Environmental Policies 390,000 Environmental Policies 150,000 Environmental Policies 120,000 Environmental Policies 120,000 4,561,315

TOTAL COSTS 14,497,238

PROFIT 3,624,310

Performance Measures Profit on Cost% 25.00% Profit on GDV% 20.00% Profit on NDV% 20.00%

IRR 68.44%

Profit Erosion (finance rate 7.000%) 3 yrs 3 mths

Appendix 6: Residual Land Value – Savills (52 Flats)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

NET REALISATION 16,318,314

OUTLAY

ACQUISITION COSTS Residualised Price (Negative land) (6,318,609) (6,318,609) CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 6,312 ft² 199.00 pf² 1,256,088 2b flat OM 11,670 ft² 199.00 pf² 2,322,330 3b flat OM 9,240 ft² 199.00 pf² 1,838,760 4b flat OM 2,013 ft² 199.00 pf² 400,587 1b flat SR 5,523 ft² 199.00 pf² 1,099,077 2b flat SR 9,336 ft² 199.00 pf² 1,857,864 3b flat SR 7,700 ft² 199.00 pf² 1,532,300 4b flat SR 4,026 ft² 199.00 pf² 801,174 1b flat Aff 789 ft² 199.00 pf² 157,011 2b flat Aff 1,167 ft² 199.00 pf² 232,233 3b flat Aff 1,540 ft² 199.00 pf² 306,460 1b flat SO 789 ft² 199.00 pf² 157,011 2b flat SO 1,167 ft² 199.00 pf² 232,233 Totals 61,272 ft² 12,193,128 12,193,128

PROFESSIONAL FEES Professional Fees 10.00% 1,219,313 1,219,313 DISPOSAL FEES Sales Agent Fee & Marketing 2.00% 271,646 Sales Legal Fee 0.50% 81,592 353,238 FINANCE

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2 - 52 Flats - RLV.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS Debit Rate 7.00% Credit Rate 0.00% (Nominal) Total Finance Cost 374,739

TOTAL COSTS 13,054,652

PROFIT 3,263,662

Performance Measures Profit on Cost% 25.00% Profit on GDV% 20.00% Profit on NDV% 20.00%

IRR N/A

Profit Erosion (finance rate 7.000%) 3 yrs 3 mths

Appendix 7: Residual Land Value – Savills (100 Flats)

Cowley Investments Ltd November 2019

APPRAISAL SUMMARY SAVILLS

Summary Appraisal for Merged Phases 1 2 3 4

Currency in £

NET REALISATION 25,963,314

OUTLAY

ACQUISITION COSTS Residualised Price (Negative land) (12,239,869) (12,239,869) CONSTRUCTION COSTS Construction ft² Rate ft² Cost 1b flat OM 12,112 ft² 199.00 pf² 2,410,288 2b flat OM 21,299 ft² 199.00 pf² 4,238,501 3b flat OM 16,258 ft² 199.00 pf² 3,235,342 4b flat OM 5,799 ft² 199.00 pf² 1,154,001 1b flat SR 9,841 ft² 199.00 pf² 1,958,359 2b flat SR 16,815 ft² 199.00 pf² 3,346,185 3b flat SR 13,302 ft² 199.00 pf² 2,647,098 4b flat SR 3,866 ft² 199.00 pf² 769,334 1b flat Aff 1,514 ft² 199.00 pf² 301,286 2b flat Aff 2,242 ft² 199.00 pf² 446,158 3b flat Aff 2,956 ft² 199.00 pf² 588,244 4b flat Aff 1,933 ft² 199.00 pf² 384,667 1b flat SO 757 ft² 199.00 pf² 150,643 2b flat SO 2,242 ft² 199.00 pf² 446,158 3b flat SO 2,956 ft² 199.00 pf² 588,244 Totals 113,892 ft² 22,664,508 22,664,508

PROFESSIONAL FEES Professional Fees 10.00% 2,266,451 2,266,451 DISPOSAL FEES

File: E:\_DEVELOPMENT AND VALUATION\_DEVELOPMENT\3 INSTRUCTED JOBS\live jobs\Oxford greyhound stadium\2019\Appraisals\Savills - Multi Phase v2 - 100 Flats - RLV.wcfx ARGUS Developer Version: 6.00.008 Date: 07/11/2019 APPRAISAL SUMMARY SAVILLS Sales Agent Fee & Marketing 2.00% 407,246 Sales Legal Fee 0.50% 129,817 537,063 FINANCE Debit Rate 7.00% Credit Rate 0.00% (Nominal) Total Finance Cost 578,682

TOTAL COSTS 20,770,656

PROFIT 5,192,658

Performance Measures Profit on Cost% 25.00% Profit on GDV% 20.00% Profit on NDV% 20.00%

IRR N/A

Profit Erosion (finance rate 7.000%) 3 yrs 3 mths

Kate McCree MRICS Matthew Davis MRICS Surveyor Associate Director

+44 (0) 18 6526 9079 +44 (0) 1865 269 077 +44 (0) 79 7237 1956 +44 (0) 7812 965 301 [email protected] [email protected]

savills.co.uk Cowley Investments Ltd November 2019

Oxford Stadium Sandy Lane Cowley Oxfordshire OX4 6LJ October 2019

The Key Remedial Works to Make Oxford Stadium Operational

The key remedial works to put the Stadium back into an operational condition are split into three main areas. These comprise (A) Refurbishment of the Main Stadium Building, (B) Refurbishment of the Terraces and Track and (C) Replacement and Refurbishment of the Infrastructure to allow Speedway and Greyhound Operations.

A. Refurbishment of the Main Stadium Building

The main stadium building was constructed in circa 1985 and extended in 2000. It provides large internal terraced viewing, private boxes and dining/bar areas. The property has been part stripped out and is now in a dilapidated condition requiring wholesale refurbishment to return it to an operational condition. The refurbishment will include renewal of internal finishes, service installations and repairs to the external fabric. We have therefore allowed for a basic refurbishment with no enhancement or alteration. The budget estimate for these works is £2,744,595.00 plus VAT and excluding professional fees.

B. External Terraces and Race Tracks

The external terraced hard standings to the perimeter of the two main race tracks are thought to date back to circa 1938. These tracks were once used for speedway and dog racing and have now fallen into decline. We would suggest a provisional cost in the region of £500,622.12 plus VAT and excluding professional fees.

C. Greyhound Racing and Speedway Racing

In addition to the main stadium being operational and in respect of the greyhound racing the paddock area will also require refurbishment to provide animal welfare facilities. The present condition is not favourable with a large collapsed tree and broken asbestos roof sheets. To bring these facilities back into a basic functional use we would expect a cost in the region of £103,844.00 plus VAT and excluding professional fees.

The speedway racing facility to the former workshop buildings located to the North West of the site will also require refurbishment/replacement due to their dilapidated condition. We would suggest a building cost in the region of £317,205.00 plus VAT and excluding professional fees. For the purposes of this exercise we have excluded any costs associated with the central go karting business and its future use.

D. There are other areas of refurbishment that would be required but are considered non-essential to the operation of the Stadium and the future use would require further consideration. A further cost of £264,222.00 plus VAT and excluding professional fees would be required to assess the remaining redundant structures.

The total estimated budget cost will be in the region of £3,930,528.12. This cost is exclusive of VAT, consultancy and statutory fees and inflation, intrusive and initial surveys.

Please Note: This summary should be read in conjunction with the Addendum Report referenced T0722 and the Condition Report referenced S0851.

Transport Technical Note

Oxford Stadium

City Planning Limited on behalf of Cowley Investments Limited

Final

7 November 2019

City Planning Ltd 2nd Floor West Wing, 40-41 Pall Mall, London, SW1Y 5JG T 020 3393 2540 W www.city-planning.co.uk

CONTENTS

CONTENTS ...... 2

1. EXECUTIVE SUMMARY ...... 4

2. INTRODUCTION ...... 6

3. EXISTING SITE AND ACCESSIBILITY ...... 8

Existing Site 8

Car 8

Cycle 9

Bus 9

Rail 10

4. PARKING STANDARDS ...... 11

5. DESKTOP RESEARCH OF COMPARABLE SITES ...... 13

6. PARKING SURVEY DATA ...... 15

Methodology 15

Results 15

Analysis 16

7. MINIMUM CAR PARKING DEMAND ASSESSMENT ...... 17

8. OFF-SITE PARKING LOCATIONS ...... 18

Off-Street Parking Locations 18

On-Street Parking Opportunities 19

9. CAR PARK LAYOUT DRAWINGS ...... 20

10. SUSTAINABLE TRANSPORT OPTIONS ...... 21

Pedestrian and Cycle Links 21

Direct Bus Services 21

Cowley Branch Line 21

Park and Ride 22

Oxfordshire Bus Rapid Transit 22

Controlled Parking Zones 22

Analysis 22

11. CONCLUSION ...... 23

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 2

Appendices

A1. PARKING SURVEY RESULTS

A2. WESTERN CAR PARK LAYOUT

A3. INDICATIVE DECKED CAR PARK DESIGN

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 3

1. EXECUTIVE SUMMARY

1.1 Oxford Stadium (‘the Site’) has been designated for redevelopment in the emerging Oxford Local Plan 2036 (Proposed Submission Draft). Oxford City Council’s (‘the City Council’s’) intention for the Site is to allow housing to be built on the western part of the Site, with the surplus from this used to finance the improvements required to bring the Stadium back into use for Greyhound racing and Speedway, in addition to events on non-race days such as conferences.

1.2 Oxford City Council’s business case for the redevelopment (the Business Case) is set out in two documents: a Commercial Viability Appraisal (CVA) prepared by Five Lines and further details provided as part of the City Council’s response to Second Set of Inspector’s Initial Questions and Comments (IC.2).

1.3 The Business Case for the Site relies on the entire western car park being redeveloped for housing, delivering a total of 52 units. This is based on a high-density assumption of 67 units per hectare, and a total area of 0.77 hectares. The City Council has also assumed that the 220 car parking spaces currently in the western car park will be reprovided at a cost of £15,000 per car parking space. No location for the replacement car parking has been identified.

1.4 The City Council anticipate that the proposed Stadium would operate Greyhound events (average 750-1,000 attendance, three per week, all year round), Speedway events (average 1,500 attendance, 22 per year), in addition to events on non-race days such as conferences and other hospitality events. As identified by the CVA, the Stadium would serve a wide catchment area – the closest existing stadium is in Swindon, 35 miles away. It is understood the capacity of the Stadium is approximately 1,500 seats, and will remain this size with the proposed redevelopment.

1.5 The latest draft of the emerging Oxford Local Plan 2036 (Proposed Submission Draft) removes all non-residential car parking standards. The presumption remains that car parking levels should be reduced wherever possible. Notwithstanding this, applications will continue to be refused where they cause an unacceptable impact on surrounding streets. It is therefore concluded that while the reprovision of the 220 spaces in the western car park may be acceptable, it would not be possible to increase this number.

1.6 A total car parking ratio of 1 space per 5 seats is considered suitable for Oxford Stadium, which includes 220 car-parking spaces on the western side of the site and 70 spaces on the eastern side. This is in line with the level of car parking provided at comparable stadia at Monmore Green in Wolverhampton (1 space per 5.3 seats) and the new development at Swindon (1 space per 4.8 seats). It means that for Speedway events, which are anticipated to attract an average of 1,500 visitors, there would be a maximum of 220 visitor car trips, which equates to an approximate car

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 4

mode share of 30-44% (based on an average car occupancy level of between 2-3 people per car). This is entirely reasonable and still relies on over half of all visitors arriving by non-car modes.

1.7 A search of the surrounding area has been undertaken to identify off-site car parking locations where replacement car parking could be provided, however none of these provide sufficient car parking within a reasonable walking distance, as would be expected by those used to more convenient and adjacent parking arrangements when attending such events. Furthermore, the residential streets surrounding the Site are unsuitable for Stadium visitor car parking during both daytime and evening periods, given the existing restrictions and residential parking requirements. Should Oxford Stadium reopen, a full review of the existing parking restrictions would need to be undertaken to ensure overspill parking does not occur to the extent that it reduces parking availability for local residents, harms highway safety and creates localised congestion.

1.8 An alternative solution has been considered, which seeks to retain the 220 car parking spaces on Site in a decked structure, and thereby release some of the western car park for residential development. Such an approach would cost no less than £3.3M as stated in the Business Case and would reduce the level of residential units that can be achieved on the Site to the detriment of the viability of the Stadium redevelopment.

1.9 Opportunities to achieve a significant mode shift towards sustainable transport options are limited without significant investment. Even with these measures in place, demand for car parking will remain for a large proportion of visitors, given the wide catchment area and likely cost and travel time benefits of car driving compared to other modes of travel.

1.10 It is the City Council’s goal to implement parking controls for the whole City by 2036. Should limited visitor parking be provided to serve the Stadium, and a Controlled Parking Zone (CPZ) be implemented on surrounding residential streets to address overspill issues, this will discourage visitors from attending events at the Site and therefore harm the viability of the Stadium through lack of attendance.

1.11 It is concluded that the existing 220 visitor spaces on the western car park would need to be replaced to support the Oxford Stadium redevelopment and that the cost of re-provision of this amount of parking will be no less than £3.3M.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 5

2. INTRODUCTION

2.1 Oxford Stadium (‘the Site’) has been designated for redevelopment in the emerging Oxford Local Plan 2036 (Proposed Submission Draft). Oxford City Council’s (‘the City Council’s’) intention for the Site is to allow housing to be built on the western part of the Site, with the surplus from this used to finance the improvements required to bring the Stadium back into use for Greyhound racing and Speedway, in addition to events on non-race days such as conferences.

2.2 Oxford City Council’s Business Case for the site is contained in two documents. In March 2018, a Commercial Viability Appraisal (CVA) was prepared by Five Lines, on behalf of the City Council, to examine the outline business case for the Site. Further details, including a financial appraisal of income and costs, were provided in 2019 in the City Council’s response to Second Set of Inspector’s Initial Questions and Comments (IC.2), in Appendix 1 (Background Information for Policy 52).

2.3 The Business Case relies on the entire western car park being redeveloped for housing, delivering a total of 52 units. This is based on a high-density assumption of 67 units per hectare, and a total area of 0.77 hectares. The City Council has also assumed that the 220 car parking spaces currently in the western car park will be reprovided at a cost of £15,000 per car parking space. No location for the replacement car parking has been identified.

2.4 The City Council anticipate that the proposed Stadium would operate Greyhound events (average 750–1,000 attendance, three per week, all year round), Speedway events (average 1,500 attendance, 22 per year), in addition to events on non-race days such as conferences and other hospitality events. As identified by the CVA, the Stadium would serve a wide catchment area – the closest existing stadium is in Swindon, 35 miles away. It is understood the capacity of the Stadium is approximately 1,5001 seats, and will remain this size with the proposed redevelopment.

2.5 This Transport Technical Note (‘the Note’) examines the Business Case with respect to transport, including an assessment of the level of car parking required, and options for providing this parking, and opportunities to reduce car parking demand through implementing sustainable transport solutions..

2.6 To assess the level of car parking required, this Note considers the following:

 The existing accessibility of the site and level of car parking permitted according to local and county planning policy (see Section 3 and 4); and

1 http://www.napit.co.uk/viewus/infobank/dogs/ukdogs/oxford.php

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 6

 The level of parking provided and used at comparable stadia sites elsewhere in the country (see Section 5, 6 and 7).

2.7 To identify options to provide this parking, this Note considers the following:

 Nearby locations which could serve either as overspill parking or fully replace the provision on site (see Section 8); and

 Car parking layouts of Oxford Stadium that seek to provide the parking on site whilst allowing opportunities for residential development (see Section 9).

2.8 Finally, sustainable transport improvements have been considered to identify whether car parking demand could be reduced whilst still retaining the visitor attraction of the Stadium (see Section 10).

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 7

3. EXISTING SITE AND ACCESSIBILITY

Existing Site

3.1 Oxford Stadium is located on Sandy Lane, in the north of the Blackbird Leys area of Oxford. A car park to the west of the Site provides a total of 220 spaces (see Figure 3.1; a more detailed layout is provided in Appendix A2). In addition, there are 70 car parking spaces to the east of the Site which have provided parking for staff, trainers and other community uses. In total, there are three vehicular accesses into the Site from Sandy Lane, and an internal access road which enables vehicles to route internally between the car parking areas. This Note focuses on the western car park, given the assumption within the Business Case that this entire area will need to be allocated for housing.

Figure 3.1: Location of the Western Car Park

Car

3.2 Oxford Stadium is easily accessible by car. It is located close to the A4142 Eastern By-Pass that runs between the A34 and A40.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 8

Cycle

3.3 Oxford has extensive cycle infrastructure, including a well-developed network of quietways. The nearest connection to this network is on Balfour Road/Blackbird Leys Road, which connects to routes to the centre of Oxford and other parts of the city.

Bus

3.4 The Site is served by a number of nearby bus routes which provide access to the City Centre and Oxford railway station. Bus stops are located on Watlington Road to the east, Balfour Road to the south, and Blackbird Leys Road to the west, as shown on Figure 3.2.

Figure 3.2: Bus Stops in Proximity to the Site

3.5 The bus services available from these stops as outlined in Table 3.1.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 9

Table 3.1: Existing Bus Services in Proximity to the Site

Distance Bus stop Routes Frequency Time to city centre from site

Transport Way 450 m 11 Hourly 20 minutes (Watlington Road)

Longlands Road 350 m 1, 5, N1 5–15 minutes 30 minutes (Balfour Road)

Sandy Lane West 5–10 minutes (1, 5) 500 m 1, 5, 12, N1 20 minutes (Blackbird Leys Road) Twice hourly (12)

Rail

3.6 The nearest rail station is Oxford, which is seven kilometres from the Site and reliant on other modes to access. Bus routes 1 and 5 continue beyond the City Centre to Oxford station.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 10

4. PARKING STANDARDS

4.1 Car parking maxima for conference centres and stadia are provided in Appendix 3 of the adopted Oxford Local Plan (2005). Both of these land uses have been identified as part of the mix of use at the Site, as provided in Table 4.1.

Table 4.1: Adopted Oxford Local Plan Maximum Car Parking Standards

Development Type Maximum Car Parking Standard

1 space per 5 seats or 1 space per 10m2 of seating/assembly floor space. Conference Centres Plus 1 space per 2 staff.

1 space per 5 seats up to 1,500 seats; 1 space per 15 seats thereafter. Stadia Plus coach parking, managed so that it will not be used for car parking.

4.2 Where sites have good access, or the potential for good access, by walking, cycling or public transport, lower levels of car parking will be sought. Lower levels of parking will not be accepted where this will cause pressure on surrounding streets.

4.3 A stadium with a maximum capacity of 1,500 seats would therefore be permitted a maximum of 300 spaces, plus coach parking.

4.4 In addition to the car parking and coach parking standards, in non-office, non-residential development, one space for powered two-wheelers will be sought per 1,000 m2 of gross external area. One cycle parking space will be sought per 10 seats for the first 1,000 seats; thereafter 1 space per 100 seats will be sought.

4.5 The latest draft of the emerging Oxford Local Plan 2036 (Proposed Submission Draft) removes all non-residential parking standards. The level of parking will instead be determined through discussion with the City Council based on the details of a transport assessment and travel plan.

4.6 The presumption remains that car parking levels should be reduced wherever possible. Notwithstanding this, applications will continue to be refused where they cause an unacceptable impact on surrounding streets. Paragraph 7.24 of the Oxford Local Plan 2036 (Proposed Submission Draft) states the City Council’s aim to cover the whole city with Controlled Parking Zones (CPZs) by 2036.

4.7 In summary, where non-residential sites are being redeveloped, an increased level of car parking will not be permitted, and a reduction in the number of spaces will be encouraged. It is therefore concluded that while the reprovision of the 220 spaces in the western car park and 70 spaces on the eastern car park may be acceptable, it would not be possible to increase this number.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 11

4.8 Oxfordshire County Council’s parking standards (as highway authority) relate only to residential developments, with no guidance given on non-residential development.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 12

5. DESKTOP RESEARCH OF COMPARABLE SITES

5.1 To inform the car parking analysis of Oxford Stadium, research has been undertaken on similar sites elsewhere in the country. This includes the Belle Vue and Owlerton stadia identified in the City Council’s CVA, Swindon and Monmore Green (which were the location for parking surveys – see section 6), and other comparable sites.

5.2 Data were collected from the City Council’s CVA, as well as from the venues’ own websites. In the case of Swindon and Monmore Green, this was supplemented by site visits. The available data are set out in Table 5.1.

Table 5.1: Comparable Site Assessment

Car Seats Type of Stadium Non-car Site Parking per Charges Events Capacity accessibility Spaces space

Coach parking Greyhound provided Swindon and 2,000 800* 2.5 Free speedway Local buses (twice hourly)

251 (plus Swindon 228 (replacement – Greyhound overflow Local buses planning and 4,500 4.8 – and 449 (twice hourly) application speedway park and pending) ride)

280 (main car park) Ten-minute Greyhound 49 (staff Monmore Green walk from and 2,000 car park) 5.3 – (Wolverhampton) Preistfield speedway 46 Metro station (trainer car park)

Three-minute Greyhound Owlerton † walk from and 4,000 ~350 11.4 £1 (Sheffield) Hillsborough speedway tram station

Belle Vue Ten-minute Speedway Speedway 6,000 160 37.5 £3 walk from Belle (Manchester) Vue rail station

Greyhound Five-minute Belle Vue Stadium and stock 4,100 400* 10.25 Free walk from Belle (Manchester) cars Vue rail station

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 13

Coach parking Greyhound Central Park provided and 6,000 ~200* 30 – (Sittingbourne) speedway Local buses (twice hourly)

Local buses Harlow Stadium Greyhound 1,500 400 3.75 – (bihourly)

Local buses Henlow Stadium Greyhound 1,500 400 3.75 – (five daily) Walking times are based on a walking speed of 4.5 kilometres per hour. * This figure is an estimate. A large part of the space given over to parking is not delineated into individual spaces. †This area is also used as car parking for other venues, and for other uses, including fun fairs.

5.3 The analysis has shown that all stadia operate with considerable levels of car parking on site, with the minimum being 160 spaces at Belle Vue Stadium in Manchester, which benefits from being walking distance from a rail station, and the maximum being approximately 800 spaces at Swindon, albeit this includes unmarked areas and 20% of spaces currently flooded.

5.4 The Swindon Stadium site is currently in the process of being redeveloped. Outline planning permission (LPA ref: S/07/1365/IH) was granted in 2011, covering a replacement stadium and surrounding residential and commercial development. A reserved matters application has also been submitted (LPA ref: S/RES/18/0027) providing extra details regarding the stadium aspect of the development, including car parking. In addition to the 479 spaces provide onsite, the Transport Assessment makes reference to an additional 449 spaces available at Copse Park and Ride for use during high-attendance events.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 14

6. PARKING SURVEY DATA

6.1 Parking surveys were undertaken at two comparable sites to better inform the assessment of parking demand for Greyhound and Speedway events.

6.2 Monmore Green in Wolverhampton and Swindon Stadium in Swindon were chosen for the surveys, due to their comparability to Oxford Stadium. Both serve medium-tier settlements (100,000 people plus) and are in out-of-centre locations. Whilst some level of public transport operates at each site, primary access is by car. Both also feature Greyhound and Speedway racing and have a comparable maximum capacity.

Methodology

6.3 Three separate counts were undertaken across two nights: on Saturday 12th October 2019 at Greyhound events in Wolverhampton and Swindon, and on Thursday 17th October 2019 at a Speedway event in Swindon. The surveys were undertaken by independent survey company MHTC Ltd.

6.4 A count of the number and occupancy of car parking spaces was undertaken before the surveys began. Where possible, this was broken down by visitor, staff and trainer/rider parking.

6.5 Surveys began at least an hour before the first race, to ensure all visitors were captured. The number of vehicle arrivals was broken down by fifteen-minute intervals and by vehicle type. Counts were undertaken at the site entrance to ensure all vehicles were captured. However, it was not possible to discern whether each vehicle was used by a visitor, member of staff or trainer.

Results

6.6 A summary of the survey results is provided in Table 6.1, with the full data provided in Appendix A1.

Table 6:1 Parking Survey Results

Stadium Event Car parking spaces Maximum utilisation

Greyhound racing 280 (plus 49 staff and 46 Wolverhampton 195 (52%) (typical) trainer)

Greyhound racing Swindon 800 142 (18%) (typical)

Swindon Speedway (final) 800 980 (123%)

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 15

Analysis

6.7 The parking survey results show that on a typical Greyhound event, parking demand was in region of 142-195 spaces. The Speedway survey has shown that on occasions, these events can generate significant levels of visitors and hence demand for parking (980 cars in the case of Swindon), sometimes in excess of the level of parking provided within the site.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 16

7. MINIMUM CAR PARKING DEMAND ASSESSMENT

7.1 The data collected from comparable sites reveal that the nature of the Greyhound and Speedway events dictate that car travel dominates as the main mode of travel for visitors. This is due to a number of factors, including the out-of-centre locations of the sites, the wide catchment areas and the timing of events at the weekend/evening, meaning that public transport does not provide an attractive alternative in terms of cost and journey times.

7.2 Whilst further data would ideally be sought on parking demand for typical Speedway events, based on the information analysed to date, it is considered that Speedway events have the potential to create more demand for parking that the Greyhound events, and at times, this can be very high (see Swindon data for the final in Table 6.1). It is therefore concluded that the 220 visitor spaces currently located within the western car park would need to be retained to ensure the Stadium can host both Greyhound and Speedway events on a regular basis, and for large events, such as a Speedway Premiership final, significant additional overspill parking would also be required.

7.3 Based on a capacity of 1,500 for the Stadium, the reprovision of 220 car parking spaces (in addition to the existing 70 car parking spaces on the eastern side of the site) would give a car-parking ratio of one car parking space for every 5.1 seats. This is in line with the level of car parking provided at comparable stadia at Monmore Green in Wolverhampton and the new development at Swindon. These sites are providing a car parking ratio of 5.3 and 4.8 respectively.

7.4 The parking ratio of 1 space per 5 seats is therefore considered suitable for Oxford Stadium and accords with the adopted local parking standards. It means that for Speedway events, which are anticipated to attract an average of 1,500 visitors, there would be a maximum of 220 visitor car trips, which equates to an approximate car mode share of 30-44% (based on an average car occupancy level of between 2-3 people per car). This is entirely reasonable and still relies on over half of all visitors arriving by non-car modes.

7.5 This analysis aligns with the assumptions within the City Council’s Business Case, which assumes that 220 car parking spaces will need to be reprovided as part of any redevelopment of the Site.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 17

8. OFF-SITE PARKING LOCATIONS

8.1 The redevelopment of the Site will involve the reprovision of 220 car parking spaces, with the existing western car park being redeveloped for housing. While £3.3 million was set aside to deliver the new parking (£15,000 per parking space), no locations for the car parking were identified by Oxford City Council.

Off-Street Parking Locations

8.2 A search of the surrounding area has been undertaken to identify off-street locations where replacement car parking could be provided. The locations identified are all existing car parks. There were no sites in the vicinity that have been identified as suitable for the development of a new car park.

8.3 The identified locations are set out on Figure 8.1.

Figure 8.1: Car Parks in Proximity to the Site

8.4 Only one location was identified within a reasonable walking distance of Site, which is the Lidl supermarket on Watlington Road, some 400 metres from Oxford Stadium (approximately a five- minute walk, labelled blue in the map above). This has 88 car parking spaces, which may include spaces for staff parking. This is significantly less than required. Additionally, the Lidl is open until 11pm Monday to Saturday, overlapping with Stadium events.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 18

8.5 Two car parks to the northwest of the site – one at Tesco and an unnamed car park next to it – could potentially provide an appropriate level of alternative car parking. However, both sites are at least 1.2 km from the Site and are therefore unsuitable for use by visitors, as the walking time (at least 15 minutes’ walk) is not at all attractive for those who will expect, and are used to, much more convenient and adjacent parking arrangements when attending such events. Additionally, an agreement would need to be reached with the current user, in the case of Tesco, or the future user, in the case of the other car park, which is due to become a motorcycle training centre in the short term and has been earmarked by the City Council as the Oxford Business Park railway halt for the Cowley branch line in the long term.

On-Street Parking Opportunities

8.6 The residential streets within a short walk from the Site (250-300 metres), including Sandy Lane, Tucker Road and Ladenham Road, are not within a formal Controlled Parking Zone (CPZ), however parking restrictions currently exist in some locations.

8.7 These restrictions are in the form of double yellow lines (restricting parking at all times, mainly along the southern side of Sandy Lane, at key junctions and at the entrance to private parking areas) and single yellow lines (restricting parking between Monday to Friday, 9am to 5pm, mainly along the north side of Sandy Lane adjacent to the Site). The residential streets further to the south, such as Tucker Road and Ladenham Road, generally do not have any parking restrictions apart from at key junctions and some on-street disabled bays. Furthermore, some private spaces have riseable bollards, which can be operated manually with a key.

8.8 The type of residential parking available is mainly on-street, in addition to some verge parking (designated and undesignated) and small car parking areas. None of these roads are wide enough to support parking on both sides. Where restrictions do not already exist, local customs and practice based on the features of the roads generally determine which side residents choose to park.

8.9 In summary, the residential streets surrounding the Site are unsuitable for Stadium visitor car parking during both daytime and evening periods, given the existing restrictions and residential parking requirements. Should Oxford Stadium reopen, a full review of the existing parking restrictions would need to be undertaken to ensure overspill parking does not occur to the extent that it reduces parking availability for local residents, harms highway safety and creates localised congestion.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 19

9. CAR PARK LAYOUT DRAWINGS

9.1 No location in the vicinity of Oxford Stadium presents itself as a suitable location for alternative car parking provision.

9.2 In an effort to ensure all options are examined, an alternative approach was pursued. This consisted of retaining the 220 car parking spaces on the western side of the Site, but within a decked structure to release some land for residential development.

9.3 An indicative layout for such a scheme is presented in Appendix A3. This design has sought to maximise land available for residential use, while providing a scheme that would be acceptable in planning terms.

9.4 This shows a decked car park at ground and first floor level, with 10% disabled spaces, and would enable direct pedestrian access to the kennels and Stadium.

9.5 The Business Case states that the cost of reproviding the 220 spaces would be £3.3M (£15,000 per space). It is considered that the two-storey decked car park design would cost no less than this amount.

9.6 This on site car park reduces the residential area from 0.77 to 0.39 hectares (as an absolute maximum). Based on the same high density assumption used in the viability report (67 units per hectare), this equates to 26 residential units (down from 52 units – exactly half).

9.7 An alternative option could be considered which adds one or two extra storeys to the decked car park. This would release some additional land for residential, however it would also increase the build costs of the car park materially, whilst still not reaching the 52 residential units assumed within the City Council’s Business Case. It should also be noted that a multi-storey car parking solution of more than two storeys would be challenging to achieve in planning terms due to the overlooking issues associated with the existing houses with rear private gardens located directly to the south.

9.8 Furthermore, it should be noted that some of the areas highlighted for residential may be undevelopable due to noise and lighting issues generated by the Stadium, and therefore the numbers presented are a ‘best case’ in terms of residential delivery.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 20

10. SUSTAINABLE TRANSPORT OPTIONS

10.1 There are no nearby locations to reprovide 220 car parking spaces, as assumed by the City’s Council’s Business Case. Additionally, attempting to provide the car parking onsite will not generate sufficient enabling development to upgrade the Stadium.

10.2 This section explores the opportunities for reducing car demand by enhancing sustainable transport options to the Site.

Pedestrian and Cycle Links

10.3 The improvement of pedestrian and cycle networks has been identified by the City Council as a priority, including in the vicinity of Oxford Stadium. Improved routes and wayfinding could encourage more visitors from across the city to visit the site by bike.

10.4 Notwithstanding the above, improved cycle and pedestrian access can only make a limited contribution to reducing car use given the wide catchment area envisioned for the Stadium.

10.5 To reach its full potential, any improvements to cycle and pedestrian infrastructure would rely on a new railway crossing to the north of the Site, to better link into existing routes to and from Oxford City Centre. No proposals are currently forthcoming from the City Council to deliver such a link.

Direct Bus Services

10.6 Direct bus services could be provided associated with the City Council’s long-term vision to reduce the number of car trips within the city and encourage sustainable transport. However, given the wide catchment for Greyhound and Speedway events, it is anticipated that the geographical location of visitors would be too dispersed to make direct bus services a viable option

Cowley Branch Line

10.7 Immediately to the north of the Site is the Cowley branch railway line. The line is currently freight only, connecting the Mini factory to the Cherwell Valley line which runs through Oxford.

10.8 There are ongoing discussions with the City Council and key stakeholders to reopen the line to passenger trains. The potential location of the proposed Oxford Business Park station is to the northeast of the Site, on the opposite side of the railway line. The journey time to Oxford station would be less than ten minutes.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 21

10.9 Upgrading the branch line and building a new station would require significant investment beyond the amounts set aside by the City Council’s for providing new parking (£3.3 million). Moreover, any service would be between the Site and Oxford centre. It would be of limited use to patrons from other parts of Oxford, or from areas outside the city not served by the rail network.

Park and Ride

10.10 A significant number of visitors to both Greyhound and Speedway events are anticipated to come from outside the City. Oxford has an established Park and Ride network to serve out-of-city visitors. However, none of the associated bus routes currently pass near the site.

10.11 The Site is located close to A4142 Eastern Bypass Road, which runs between the Redbridge and Thornhill park and ride sites. There is the potential for an event-day special service to minimise the need for onsite car parking for out-of-town visitors, however the bus journey times (approximately 20 minutes each way) are likely to deter visitors from using a P&R service. Furthermore, the Stadium would need to subsidise the bus service provision, thus impacting the Business Case.

Oxfordshire Bus Rapid Transit

10.12 In its Oxfordshire 2050 transport strategy, Oxfordshire County Council has identified a medium-term vision to deliver a bus rapid transit (BRT) network connecting Oxford and surrounding towns. This has the potential to serve Oxford Stadium, however the programme for delivery and funding mechanisms are not currently committed.

Controlled Parking Zones

10.13 It is the City Council’s goal to implement parking controls for the whole City by 2036. Should limited visitor parking be provided to serve the Stadium, and a Controlled Parking Zone (CPZ) be implemented on surrounding residential streets to address overspill issues, this will discourage visitors from attending events at the Site and therefore harm the viability of the Stadium through lack of attendance.

Analysis

10.14 A number of options exist to improve sustainable transport connections to the Site and to reduce the demand for car parking. However, all of them require significant investment, which has not been accounted for in the City Council’s Business Case. Furthermore, even with these measures in place, there will still be significant demand for car driving given the wide catchment of the Stadium and relative journey time and cost benefits of car use compared to other modes of travel, especially during the weekend and in the evening.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 22

11. CONCLUSION

11.1 It is concluded that the existing 220 visitor spaces on the western car park would need to be replaced to support the Oxford Stadium redevelopment and that the cost of re-provision of this amount of parking will be no less than £3.3M.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 23

A1. PARKING SURVEY RESULTS

A1.1 Monmore Green Stadium, Wolverhampton. Saturday, 12th October, 2019. Greyhound racing.

Period

1945 1930 1915 1900 1845 1830 1815 1800 1745 1730

Total

Time Time

2000 1945 1930 1915 1900 1845 1830 1815 1800 1745

– – – – – – – – – –

149 Car

12 14 19 30 32 20

4 2 7 9

Taxi

48 11 13

0 0 1 0 3 4 9 7

LGV

6 1 0 0 0 2 0 1 0 1 1

OGV1

0 0 0 0 0 0 0 0 0 0 0

InboundCount

OGV2

0 0 0 0 0 0 0 0 0 0 0

PSV

4 0 0 0 0 0 0 0 0 2 2

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

Site Access Site

1 0 0 0 0 0 0 0 1 0 0

Total

207

17 18 29 37 46 36

5 2 8 9

Car

3 1 3 2 1 4 5 1 3 6

Taxi

46 11 12 10

0 0 1 0 2 4 6

LGV

6 0 0 1 0 0 0 1 0 0 1

OGV1

OutboundCount

0 0 0 0 0 0 0 0 0 0 0

OGV2

0 0 0 0 0 0 0 0 0 0 0

PSV

4 0 0 0 0 0 0 0 1 2 1

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

0 0 0 0 0 0 0 0 0 0 0

Total

85 17 17 18

4 3 5 2 3 8 8

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 24

A1.2 Car Park Occupancy

Period

Time Time

2000 1945 1930 1915 1900 1845 1830 1815 1800 1745 1730

164 163 162 158 151 140 130 116 Car

87 58 44

Taxi

2 2 2 2 2 1 1 3 2 3 0

LGV

29 29 31 32 32 30 30 30 30 29 29

OGV1

0 0 0 0 0 0 0 0 0 0 0

Site Site

Vehiclesonsite

Car P

OGV2

0 0 0 0 0 0 0 0 0 0 0

ark

PSV

0 0 0 0 0 0 0 0 1 1 0

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

3 3 3 3 3 3 3 3 2 2 2

Total

195 194 195 192 185 171 161 149 120

91 73

%full

52% 52% 52% 51% 49% 46% 43% 40% 32% 24% 19%

A1.3 Monmore Green Stadium had a total of 375 car parking spaces: 280 spaces for visitors, 49 spaces for staff and 46 spaces for trainers.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 25

A1.4 Swindon Stadium, Swindon. Saturday, 12th October, 2019. Greyhound racing.

Period

1945 1930 1915 1900 1845 1830 1815 1800 1745 1730

Total

Time Time

2000 1945 1930 1915 1900 1845 1830 1815 1800 1745

– – – – – – – – – –

128 Car

17 14 26 16 18 11 11

6 3 6

Taxi

0 0 1 2 2 1 1 4 3 1

LGV

0 0 2 0 0 2 1 2 0 6

OGV1

0 0 0 0 0 0 0 0 0 0 0

nboundCount

OGV2

0 0 0 0 0 0 0 0 0 0 0

PSV

4 0 0 1 0 1 1 0 1 0 0

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

Site Access Site

1 0 0 0 0 0 0 0 1 0 0

160

otal

10 19 17 30 18 25 14 18

6 3

Car

3 2 3 3 1 0 2 3 2 1

Taxi

0 0 1 3 1 2 0 4 3 1

LGV

2 0 0 0 0 0 0 1 0 1 0

OGV1

OutboundCount

0 0 0 0 0 0 0 0 0 0 0

OGV2

0 0 0 0 0 0 0 0 0 0 0

PSV

0 0 0 0 0 0 0 0 0 0 0

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

0 0 0 0 0 0 0 0 0 0 0

Total

3 2 4 6 2 2 3 7 6 2

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 26

A1.5 Car park occupancy

Period

Time Time

2000 1945 1930 1915 1900 1845 1830 1815 1800 1745 1730

127 124 123 120 106 Car

93 67 53 38 29 19

Taxi

0 0 0 0 1 0 1 0 0 0 0

LGV

11 11 11

9 9 9 7 7 5 6 0

OGV1

0 0 0 0 0 0 0 0 0 0 0

Site Site

Vehiclesonsite

Car Park

OGV2

0 0 0 0 0 0 0 0 0 0 0

PSV

4 4 4 3 3 2 1 1 0 0 0

MCL

0 0 0 0 0 0 0 0 0 0 0

PCL

1 1 1 1 1 1 1 1 0 0 0

Total

142 139 138 132 119 104

76 61 43 35 19

%full

18% 17% 17% 17% 15% 10%

13&

8% 5% 4%

A1.6 Swindon Stadium had 800 spaces, including marked and unmarked areas. Heavy rain and animal rights protestors may have limited attendance.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 27

A1.7 Swindon Stadium, Swindon. Thursday, 17th October, 2019. Speedway Premiership final.

Period

1915 1900 1845 1830 1815 1800

Total

Time Time

1930 1915 1900 1845 1830 1815

– – – – – –

513 119 133 132 Car

10 46 73

Taxi

4 0 1 0 0 1 2

LGV

58 15 16 11 12

0 4

OGV1

0 0 0 0 0 0 0

InboundCount

OGV2

0 0 0 0 0 0 0

PSV

0 0 0 0 0 0 1

MCL

0 2 2 3 3 2

PCL

Site Access Site

1 0 0 0 1 0 0

Total

589 136 153 147

10 53 90

Car

8 0 1 2 0 2 3

Taxi

4 0 1 0 0 2 1

LGV

0 0 0 0 0 0 0

OGV1

OutboundCount

0 0 0 0 0 0 0

OGV2

0 0 0 0 0 0 0

PSV

0 0 0 0 0 0 0

MCL

0 0 0 0 0 0 0

PCL

0 0 0 0 0 0 0

Total

0 2 2 0 4 4

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 28

A1.8 Car park occupancy

Period

Time Time

1930 1915 1900 1845 1830 1815 1800

891 881 836 719 586 456 386 Car

Taxi

0 0 0 0 0 1 0

LGV

68 68 64 49 33 22 10

OGV1

0 0 0 0 0 0 0

Site Site

Vehiclesonsite

Car Park

OGV2

0 0 0 0 0 0 0

PSV

5 5 5 5 5 5 4

MCL

16 16 14

2 9 6 4

PCL

1 1 1 1 0 0 0

Total

980 970 919 785 633 490 404

123% 121% 115%

%full

98% 79% 61% 51%

A1.9 Swindon Stadium had 800 spaces, including marked and unmarked areas. The event was the final of Speedway Premiership Cup, which would have boosted attendance. The demand for parking exceeded the space available at the site. At the end of the evening over 150 vehicles were parked outside on Lady Lane.

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 29

A2. WESTERN CAR PARK LAYOUT

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 30

A3. INDICATIVE DECKED CAR PARK DESIGN

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 31

Transport Technical Note (7 November 2019) | City Planning Limited on behalf of Cowley Investments Limited 32

OXFORD GREYHOUND STADIUM Bickerdike Allen Partners LLP is an integrated practice of Architects, Acousticians, and Construction PROPOSED RESIDENTIAL DEVELOPMENT Technologists, celebrating over 50 years of

continuous practice.

ENVIRONMENTAL NOISE ASSESSMENT Architects: Design and project management services

which cover all stages of design, from feasibility and planning through to construction on site and

completion.

Acoustic Consultants: Expertise in planning and

noise, the control of noise and vibration and the sound insulation and acoustic treatment of buildings.

Construction Technology Consultants: Expertise in building cladding, technical appraisals and defect

investigation and provision of construction expert witness services.

Report to

Cowley Property Investment Limited Sterling House Langston Road Loughton IG10 3TS

A11246_01_RP005_2.0 8th November 2019

Contents Page No.

1.0 Introduction ...... 3

2.0 The Site ...... 3

3.0 Criteria ...... 3

4.0 Noise & Vibration Surveys ...... 5

5.0 Acoustic Modelling & Mitigation ...... 6

6.0 Summary ...... 12

Appendices

Appendix 1: Glossary of Acoustic Terminology

Appendix 2: Baseline noise and vibration assessment

Appendix 3: Speedway reference noise levels

Appendix 4: Sittingbourne speedway noise level survey

Appendix 5: Peterborough greyhound noise level survey

This report and all matters referred to herein remain confidential to the Client unless specifically authorised otherwise, when reproduction and/or publication is verbatim and without abridgement. This report may not be reproduced in whole or in part or relied upon in any way by any third party for any purpose whatsoever without the express written authorisation of Bickerdike Allen Partners LLP. If any third party whatsoever comes into possession of this report and/or any underlying data or drawings then they rely on it entirely at their own risk and Bickerdike Allen Partners LLP accepts no duty or responsibility in negligence or otherwise to any such third party. Bickerdike Allen Partners LLP hereby grant permission for the use of this report by the client body and its agents in the realisation of the subject development, including submission of the report to the design team, contractor and sub-contractors, relevant building control authority, relevant local planning authority and for publication on its website.

A11246_01_RP005_2.0 Page 2

1.0 INTRODUCTION Oxford Greyhound Stadium is on the east border of the site. The Stadium is currently closed. BAP understand that there is an ambition on behalf of the Council to reopen the stadium. If Bickerdike Allen Partners LLP (BAP) has been appointed by Cowley Property Investment Limited reopened, the track could host greyhound racing, speedway and go-karts. to carry out an environmental noise assessment in relation to the Oxford Greyhound Stadium Site, Sandy Lane, Oxford. The current proposal includes retaining the Greyhound/Speedway Further north lies the Oxford Retail park. The largest premises of which is the Tesco Stadium and building new homes within the area which currently forms the stadium car park. supermarket and car park. During the survey on the site noise from car park and service yard was inaudible. Continuous plant noise from the retail park was just audible at the perimeter. This report has been prepared specifically in response to instructions received from Cowley Property Investment Limited and is not intended for any other purpose. Survey work carried BAP understand that the development could comprise either a 52 unit residential scheme or a out in connection with this commission is limited in extent to the scope of those instructions. A 100 unit residential scheme at the western end of the site. glossary of acoustic terminology is included in Appendix 1. 3.0 CRITERIA 2.0 THE SITE 3.1 Oxford Local Plan 2036 – Proposed Submission Draft A layout of the site can be seen below in Figure 1. The site is in a mixed-use area of Eastern Oxford close to the A4142 Eastern Bypass and the Cowley BMW/Mini factory. BAP understand that local policy on noise is set out in the Local Plan 2036. Relevant policies are reproduced below.

“Policy RE7: Managing the impact of development Planning permission will only be granted for development that: a) ensures that the amenity of communities, occupiers and neighbours is protected; and b) does not have unaddressed transport impacts affecting communities, occupiers, neighbours and the existing transport network; and c) provides mitigation measures where necessary..”

“Noise and vibration

4.26 Noise and vibration have a significant effect on amenity and people’s health and wellbeing. The management of noise should be an integral part of development proposals and considered as early as possible. The management of noise is about encouraging the right acoustic environment in the right place at the right time. This is important to promote good health and a good quality of life within the wider context of achieving sustainable development. Managing noise includes improving and enhancing the acoustic environment and promoting appropriate soundscapes. This can mean allowing some places or certain times to become noisier within reason, whilst others become quieter.

4.27 Consideration of existing noise sensitivity within an area is important to minimise potential conflicts of uses or activities. The City Council will seek to ensure that noise sensitive developments (residential, educational and health care facilities) are separated from major sources of noise, or that appropriate attenuation measures are taken. Such attenuation measures should be included on plans. In cases where noise sensitive development is proposed Figure 1: Existing Site Layout (Highlighted in Red Line) in close proximity to an existing noise generating use (e.g. music venues and pubs) the Council The area to the south of the site is residential. There is a railway line at the northern boundary will consider whether the introduction of the sensitive use might threaten the continued of the site. This is used exclusively for rail freight to the BMW/Mini factory. BAP have been operation of the existing premises, which might mean the development is inappropriate in that informed that there are currently approximately three train movements per day at around location. Measures to mitigate the impacts of noise and vibration associated with demolition 01:00, 07:00 and 09:00. BAP understand that recent developments at the Mini factory will result and construction will be secured by legal agreement through Construction Management Plans in an increase in rail freight and this will be in the order of 6 movements per day. It is feasible which form part of the Transport Assessment.” that this line could be used in the future for passenger traffic.

A11246_01_RP005_2.0 Page 3

“Policy RE8: Noise and vibration Planning permission will only be granted for development on health, living conditions and the natural environment, as well as the potential sensitivity of proposals which manage noise to safeguard or improve amenity, health, and quality of life. the site or the wider area to impacts that could arise from the development. In doing so they should: Planning permission will not be granted for development that will generate unacceptable noise and vibration impacts. • mitigate and reduce to a minimum potential adverse impacts resulting from noise from Planning permission will not be granted for development sensitive to noise in locations which new development – and avoid noise giving rise to significant adverse impacts on health 1 experience high levels of noise, unless it can be demonstrated, through a noise assessment, that and the quality of life ; appropriate attenuation measures will be provided to ensure an acceptable level of amenity for • identify and protect tranquil areas which have remained relatively undisturbed by noise end users and to prevent harm to the continued operation of existing uses. and are prized for their recreational and amenity value for this reason; and

Conditions will be used to secure such mitigation measures and operational commitments. • limit the impact of light pollution from artificial light on local amenity, intrinsically dark Measures to mitigate the impacts of noise and vibration associated with demolition and landscapes and nature conservation” construction will be secured by legal agreement through Construction Management Plans (Refer 3.3 Noise Policy Statement for England (NPSE) to Policy T2).” The Noise Policy Statement for England (NPSE) provides the framework for noise management There is also guidance on the potential use of the Cowley Branch Line reproduced below. decisions to be made that ensure noise levels do not place an unacceptable burden on society. “The Plan will ensure, through the site allocation policies, that no development takes place The stated aims of the Noise Policy Statement for England are to: which would inhibit the opening of the Cowley Branch Line to passenger traffic, by preventing developments which would be sensitive to noise and vibration close to the railway. The Plan will • Avoid significant adverse impacts on health and quality of life from environmental, also look to safeguard bus, taxi and pedestrian and cycle routes to the rail halts, ensuring that neighbour and neighbourhood noise within the context of Government policy on sites around the new stations are as permeable as possible to enable good access.” sustainable development;

This report assesses noise and vibration from the existing use of the Cowley Branch Line by Rail • Mitigate and minimise adverse impacts on health and quality of life from freight. Passenger traffic is expected to generate lower levels of vibration than freight environmental, neighbour and neighbourhood noise within the context of Government movements. Noise maxima from individual passbys of passenger trains are unlikely to be louder policy on sustainable development; and; than freight trains. However, the increase in rail traffic could increase the overall noise levels. • Where possible, contribute to the improvement of health and quality of life through 3.2 National Planning Policy Framework (NPPF) the effective management and control of environmental, neighbour and neighbourhood noise within the context of Government policy on sustainable The National Planning Policy Framework (NPPF) published February 2019, sets out the development. Government's planning policies for England and how these are expected to be applied. With In respect of achieving the first aim above, the NPSE defines the Significant Observed Adverse regards to environmental noise assessment the NPPF states: Effect Level (SOAEL) as “This is the level above which significant adverse effects on health and 170 “Planning policies and decisions should contribute to and enhance the natural and local quality of life occur”. No objective guidance has been provided to enable policy makers, noise environment by: practitioners and decision makers to understand what this threshold level is. The document e) preventing new and existing development from contributing to, being put at unacceptable advises that in the absence of such guidance the lack of any objective guidance provides risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution “necessary policy flexibility”. or land instability. Development should, wherever possible, help to improve local environmental

conditions such as air and water quality, taking into account relevant information such as river 3.4 BS 8233:2014 basin management plans; and…” BS 8233:2014 “Guidance on sound insulation and noise reduction for buildings” provides 180 “Planning policies and decisions should also ensure that new development is appropriate information on the control of external noise. The standard presents design ranges deemed for its location taking into account the likely effects (including cumulative effects) of pollution acceptable for indoor noise levels in spaces when they are unoccupied. These are generally in

1 See Explanatory Note to the Noise Policy Statement for England (Department for Environment, Food & Rural Affairs, 2010) A11246_01_RP005_2.0 Page 4 keeping with guidance set by the World Health Organisation (WHO). The criteria from the The references above 25, 26 and 27 do not provide guidance on noise from speedway, standard relevant to this site, along with the associated Note 4, have been presented in Table greyhound racing or go-kart operation. 1. The standard advises that “In general, for steady external noise sources, it is desirable that the internal ambient noise level does not exceed the guideline values in Table 1”. 4.0 NOISE & VIBRATION SURVEYS

Activity Location 0700 to 2300 2300 to 0700 4.1 On-site baseline – road & rail

Resting Living room 35 dB LAeq,16hr - On site baseline noise and vibration surveys were carried out in 2013 and 2014. These are

Dining Dining room/area 40 dB LAeq,16hr - presented in Appendix 2. Vibration from passing freight trains was not found to be significant.

Sleeping (daytime resting) Bedroom 35 dB LAeq,16hr 30 dB LAeq,8hr 4.2 Off-site speedway/greyhound

Table 1: BS 8233:2014 Recommended Indoor Ambient Noise Levels in Unoccupied Spaces If Oxford Greyhound Stadium is allocated for continued greyhound/speedway use according to Oxfordshire County Council’s Local Plan, the proposed residential units would be exposed to Note 4: Regular individual noise events (for example, scheduled aircraft or passing trains) can noise originating from the stadium during speedway, go-karting and greyhound meetings. cause sleep disturbance. A guideline value may be set in terms of SEL or LAmax,F, depending on Speedway and go-kart noise exposure will be higher than road and rail noise at the proposed the character and number of events per night. Sporadic noise events could require separate properties on the site. values. Part way through 2018 BAP were instructed to assess the impact of speedway use on the BS8233:2014 also provides guidance on gardens/amenity spaces. “For traditional external development site. At the time the season for Speedway racing had finished. Direct areas that are used for amenity space, such as gardens and patios, it is desirable that the measurement of source noise levels for modelling was therefore not possible at another external noise level does not exceed 50 dB LAeq,T, with an upper guideline value of 55 dB LAeq,T operational speedway track. BAP therefore adopted noise measurements carried out by others which would be acceptable in noisier environments. However, it is also recognized that these in relation to a planning application for the Belle Vue Speedway in Manchester. The noise data guideline values are not achievable in all circumstances where development might be desirable. is included in Appendix 3. In higher noise areas, such as city centres or urban areas adjoining the strategic transport network, a compromise between elevated noise levels and other factors, such as the 4.3 Noise survey Speedway racing convenience of living in these locations or making efficient use of land resources to ensure development needs can be met, might be warranted. In such a situation, development should As the 2018 assessment was based on measurements carried out by others BAP were be designed to achieve the lowest practicable levels in these external amenity spaces, but should subsequently instructed in 2019 to carry out a noise survey of typical speedway racing not be prohibited.” operational activity. This was to check/validate the earlier noise modelling that was based on operational noise data from others. Based on the superseded 1999 version of BS8233 and World Health Organisation guidelines Attended measurements were carried out both on and off the site in Sittingbourne. The noise BAP recommend adopting a guideline that 45 dB LAF,max should not be regularly exceeded at night within bedrooms. data from speedway activity is presented in BAP report reference A11246_01_RP002_1.0 dated 9th October 2019 which is included in Appendix 4. Noise measurements for a typical speedway The above internal noise standards should be achieved with windows closed and adequate meeting were measured at a position approximately 45 m from the centreline of the speedway ventilation provided (e.g. trickle ventilators complying with Building Regulations Approved track. Noise measurements during a typical 90 s speedway race were measured to be Document F). 86 dB LAeq,90s. Noise measurements when assessed over a 60-minute period including PA

With regards to noise from sport BS 8233:2014 advises that: announcements and amplified music were measured to be 81 dB LAeq,1h.

“Other noise sources exist, many of which originate from leisure activities, e.g. model aircraft, 4.4 Noise survey Greyhound racing sports and entertainment. Codes of practice give guidance on likely noise levels, assessment and frequency of occurrences for most of these noise sources [for example, 25, 26, 27]. Specialist BAP were instructed in 2019 to carry out a noise survey of typical greyhound racing operational advice might be required. NOTE Codes produced by the Government can normally be obtained activity. Attended measurements were carried out both on and off the site in Peterborough. from The Stationery Office, and additional advice might be available from local authority The noise data from Greyhound racing activity is presented in BAP report reference th environmental health departments.” A11246_01_RP003_1.0 dated 16 October 2019 which is included in Appendix 5.

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The majority of customers used the bars and restaurants inside the stadium building which is 5.2 2019 Assessment enclosed with large glazed windows, similar to Oxford. A small number of customers used the To model the noise levels on the proposed development CadnaA ISO9613 noise modelling external seating area for gambling/spectating/smoking and some crowd noise results. software was used to create a computer model of the area including the stadium and the During the survey there was no external amplified music. There was a PA system with proposed dwellings. A 3D view of the model is shown in Figure 3. This includes residential loudspeakers mounted in the roof/awning of the stadium. These were used for intermittent development on the western end of the site. announcements and for race commentary. BAP have reviewed the speedway noise prediction model, which utilised the Belle Vue data, Noise measurements when assessed over a 60-minute period including PA announcements and against the recent 2019 Sittingbourne speedway measured noise data. This demonstrated that

amplified music were measured to be 79 dB LAeq,1h. This was at a worst-case location within the the noise model was predicting a level of 86 dB LAeq,90s at a location 45 m from the centre of the stadium near to customers and PA loudspeakers. speedway track. The noise prediction model (based on Belle Vue data measured by others) is consistent with noise data measured by BAP. 5.0 ACOUSTIC MODELLING & MITIGATION

5.1 Previous assessment

BAP previously carried out an assessment in December 2018. As noted in Section 4.2 this adopted noise measurements carried out by others. Specifically, noise levels recorded by consultants Vanguardia at Belle Vue on the evening of Wednesday 20th July 2011 during a speedway meeting were used. Typical Speedway races resulted in short term noise levels of

around 93 dB LAeq,1.5min in the centre of the circuit.

The conclusion of this assessment was that development on the eastern perimeter of the site was likely to result in an unacceptable noise impact for any proposed residential use. Noise

levels of around 80 dB LAeq,1 were predicted and would require severe noise control measures such as a large single aspect barrier block building with high acoustic performance windows and alternative means of ventilation and/or cooling.

Figure 3: 3D View of Noise Model

Figure 2: Noise constrained parcel of land

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5.3 Modelling results

BS8233:2014 guideline noise levels are used for steady transportation noise sources and are presented in terms of a 16-hour daytime energy average and an 8-hour energy average. The assessment time period has a substantial influence on the result. Speedway race meets consist of 15 races, with each race lasting one and a half minutes, and with a 5-minute break between each race. In our opinion a 16-hour daytime average will not be representative of typical speedway activity as the 16-hour daytime average period will dilute the noise effect over the entire day.

Similarly, a 1.5-minute average period to reflect a typical race duration is too onerous as this does not reflect the 5-minute periods of respite between the races. Although we would expect that amplified music and/or amplified speech from the PA system would be produced between races. BAP therefore recommend a one-hour assessment period. This would allow for up to 10 Speedway races or a total of 15-minute racing time.

Predictions have been made of typical levels during a speedway race. To correct to a one-hour noise metric a -6-dB correction factor needs to be applied. The predictions have been made using the ISO 9613 calculation method and the contours shown at ground floor level. Contours have been produced on the following pages showing free-field sound levels predicted outside existing and proposed dwellings. The noise contours show typical sound levels from Speedway use. Based on similar Speedway sites BAP would envisage around 20 meetings during the racing season from March to October.

Noise levels were measured to be 6 dB LAeq,1h lower within a stadium for greyhound racing. The number of meetings could be much higher. BAP would envisage that Greyhound use could typically be three evenings per week. Race commentary and announcements via the PA system have the potential to create annoyance and nuisance to nearby dwellings, existing and proposed. The PA system at the stadium includes distributed pole mounted loudspeakers around the entire perimeter at high level including on the boundary between the stadium and the suggested red line application site. Predicted greyhound noise levels are expected to be

around 5-10 dB LAeq lower than those predicted for speedway meetings.

A11246_01_RP005_2.0 Page 7 30624050 30624100 30624150 30624200 30624250 30624300 30624350 30624400 30624450 30624500 30624550 30624600 5732300 5732300 5732250 5732250 5732200 5732200

5732150 92.9 5732150

66.9 5732100 5732100 58.9

50.0 51.8 88.8 52.5 53.6 77.1 72.8 74.2 56.6 55.1 71.6 60.0 58.3

5732050 51.9 5732050 54.0 72.1 52.5

76.2 77.4 58.8 56.6 76.4 59.5 5732000 5732000

30624050 30624100 30624150 30624200 30624250 30624300 30624350 30624400 30624450 30624500 30624550 30624600 A11246_01_RP005_2.0 Speedway Noise Oxford Greyhound Stadium Difference in LAeq,1.5min dB(A) Receiver height 1.5m Grid spacing 1 x 1m [-6 dB correction needs to be applied for LAeq,1hr metric]

> -99.0 dB dB(A) > 35.0 dB dB(A) Speedway Noise - Oxford Greyhound Stadium > 40.0 dB dB(A) > 45.0 dB dB(A) > 50.0 dB dB(A) > 55.0 dB dB(A) > 60.0 dB dB(A) > 65.0 dB dB(A) > 70.0 dB dB(A) > 75.0 dB dB(A) > 80.0 dB dB(A) CadnaA noise contours > 85.0 dB dB(A) 30624050 30624100 30624150 30624200 30624250 30624300 30624350 30624400 30624450 30624500 30624550 30624600 5732300 5732300 5732250 5732250 5732200 5732200

5732150 92.9 5732150

66.9 5732100 5732100 58.9

50.0 51.8 88.8 52.5 53.6 77.1 72.8 74.2 56.6 55.1 71.6 60.0 58.3

5732050 51.9 5732050 54.0 72.1 52.5

76.2 77.4 58.8 56.6 76.4 59.5 5732000 5732000

5.4 Assessment and mitigation measures The exception is a small area to the South West where noise can leak via gaps between buildings, and/or gaps in perimeter fences. Predicted noise levels here are substantial and Existing dwellings exceed recommended guidelines by a very large margin. As a guideline as to what is a “reasonable” level of sound BS8233:2014 recommends that noise Noise levels at the recently constructed “Greyhound View” inset development of 6 dwellings levels inside living rooms or bedrooms during the day should be around 35 dB LAeq, T for on the north side of Sandy Lane are also substantial with predicted levels of around 70 dB LAeq,1h “desirable” levels and 40 dB LAeq,T for “reasonable” conditions. Assuming a scenario with and the rear flats of Holly Court will also exceed reasonable guidelines. windows open these reasonable internal levels of 40 dB LAeq would equate to external levels of

between 50-55 dB LAeq. Although it should be noted that these guidelines usually apply to Gardens and amenity areas steady transportation noise sources and not noise from sport/recreation. BS8233:2014 recommends that for traditional external areas that are used for amenity space, With a few exceptions the existing dwellings are not exposed to high levels of sound from the such as gardens and patios, it is desirable that the external noise level does not exceed Stadium. For many houses along Sandy Lane predicted sound levels are around 50- 50 dB LAeq,T, with an upper guideline value of 55 dB LAeq,T which would be acceptable in noisier

56 dB LAeq,1.5min or 44-50 dB LAeq,1hr. environments.

The 30 dwellings at 68-126 (even) Sandy Lane are all exposed to exceed the recommended For the existing dwellings on Sandy Lane the front gardens will exceed this guideline by a guideline. These dwellings are assumed to have been constructed in the 1970s with no specific substantial margin. These levels are already exceeded by road traffic noise. The rear gardens measures to mitigate against operational noise from the stadium. for the Sandy Lane dwellings will benefit room incidental noise screening provided by the terraced dwellings and are likely to meet guideline values. There are also 6 recently constructed (post 2010) houses inset into the car park area appropriately named 1-6 Greyhound View. BAP understand that the planning application For the existing dwellings on Greyhound View (inset into the car park) the rear gardens will be reference was 11/00864/FUL and an earlier 2010 application was refused. A planning condition exposed to levels that substantially exceed recommended guidelines (up to 71 dB LAeq,1h). These was set (16) so that the dwellings would achieve BS8233 recommended internal noise levels dwellings already have some mitigation in the form of a boundary fence. It will not be with windows closed and ventilation provided. A noise assessment was submitted (February reasonably practicable to reduce noise levels in the garden further and there will be a significant 2014). When the noise assessment was carried out the Greyhound Stadium was closed and adverse residual effect for many weekend and weekday evenings. therefore adequate mitigation against stadium use was not provided. The dwellings have a standard building envelope with no acoustic enhancements.

As a guide as to what has previously been considered acceptable, use of the Stadium site for go-karting was granted in 1997 with a condition on noise levels. Local authority reference 97/00788/NF. Condition 3 is reproduced below.

“3. Noise from operations conducted on the premises shall not exceed 52 dB LAeq,15min measured

at one metre from the façade of the nearest dwelling between 0800-2000 and 45 dB LAeq, 15min at nay other time.

Reason: To protect the amenities of occupiers of nearby properties.”

This noise limit for go-karting is consistent with BAP’s guideline for reasonable levels assuming

windows open of 50-55 dB LAeq.

The noise modelling of speedway levels demonstrates that this guideline level will generally be met for most existing dwellings on Sandy Lane. Although activity sound levels are very high

(93 dB LAeq on site) the incidental noise screening provided by the Stadium building, surrounding perimeter walls and nearby industrial buildings helps to reduce noise levels in addition to the separation distance.

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Proposed dwellings reduce the need to have windows open. This would require the use of mechanical ventilation and/or air conditioning. A single aspect design above could mitigate this The proposed development will result in potentially many of the new dwellings being exposed adverse effect if there are sufficient windows on the shielded south and west facades. to substantial levels of noise from use of the Stadium. With the dwellings on the north and east facades of the block, which face the stadium, predicted to be exposed to levels of around 67- • High acoustic performance building envelope – Any windows to noise sensitive

68 dB LAeq,1h. habitable rooms which overlook the stadium would require high acoustic performance These are the levels predicted at ground floor level where there is a small amount of incidental windows (potentially including secondary glazing) to reduce the levels of noise inside noise screening provided by the terraces at the western boundary of the greyhound track. the dwellings. All ventilation paths would need to be acoustically treated.

At higher floor levels there will be no incidental noise screening as the façade will overlook the • Habitable rooms on the south and west facades will still require acoustic mitigation to stadium, so for the 10th floor noise levels are predicted to be 4 dB higher than at the ground reduce noise levels from road traffic to comply with recommended internal noise floor. standards (BS8233:2014). This is likely to require windows with a reasonable level of acoustic performance (≥ 35 dB Rw AND ≥31 dB Rw+Ctr) and noise via any ventilation These levels of noise are likely to be unacceptable to future occupants without substantial noise paths would need to be limited (typically via a single ventilation opening per habitable mitigation measures. With any windows which overlook the stadium open noise levels inside room with a performance of ≥40 dB Dn,e,w). A full detailed assessment and scheme of rooms could be around 58-62 dB LAeq. It will be difficult to have a conversation on the phone or sound insulation in accordance with BS EN ISO 12354:2017 would need to be carried with people inside the homes at these levels even with raised voices. out during the detail design process.

With conventional building envelope design noise levels could be reduced by around 25-30 dB Gardens and amenity areas depending on the detailed design and ventilation arrangements. Internal noise levels with The large block of flats does not appear to have any dedicated private gardens or communal windows closed would therefore be around 38-42 dB LAeq,1h. external amenity spaces. Due to operational noise from the stadium it will not be possible to These internal levels significantly exceed the desirable 35 dB LAeq, T benchmark and approach meet recommended BS8233:2014 guidelines levels. Perimeter fencing will help to reduce noise and marginally exceed the reasonable guideline 40 dB LAeq,T. It is feasible that recommended levels as far as reasonably practicable but sound levels are still likely to be unacceptable. internal noise standards could be achieved with an enhanced acoustic performance building envelope. This would however rely on future residents having their windows closed and For the proposed dwellings on Greyhound View (inset into the car park) the rear gardens will alternative provisions for ventilation would be needed. be exposed to levels that substantially exceed recommended guidelines (up to 71 dB LAeq,1h). These dwellings can have some mitigation in the form of a boundary fence. It will not be The noise levels on the shielded façades are substantially lower due to the incidental screening reasonably practicable to reduce noise levels in the garden further and there will be a significant provided by the block itself. The predicted levels would be around 46-48 dB LAeq,1h and well adverse residual effect for many weekend and weekday evenings. within the BAPs recommended guidelines. It is therefore potentially feasible to mitigate against the adverse effects of the operation of the stadium with the layout of the noise sensitive habitable rooms within the development.

It is feasible to build homes on this site and achieve reasonable acoustic conditions for future residents, but the following would be needed,

• Agreement/discussion with the local authority on reasonable acoustic design standards for noise and ventilation.

• Single aspect design dwellings – The current proposals include dwellings which generally do not have noise sensitive rooms such as bedrooms and living rooms facing the Stadium Site. There would ideally be no noise sensitive rooms overlooking the Stadium, with any windows to less sensitive rooms such as bathrooms or hallways.

• Cooling/ventilation – Noise levels in rooms with a direct line of sight to the track are likely to exceed guideline noise levels inside dwellings with windows open. To reduce this adverse effect the dwellings are likely to need ventilation and/or cooling that will

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6.0 SUMMARY

Bickerdike Allen Partners LLP have carried out a noise assessment at the Oxford Greyhound Stadium site. Noise and vibration surveys have been previously been carried out on this site for road and rail noise and reported by BAP. These have been reproduced in this report. The assessment found that recommended guidelines for reasonable acoustic conditions to protect residents from rail and traffic noise can be achieved for future residents through the design of the development.

The proposed development on this site has changed. It is now proposed to build new dwellings within the Greyhound Stadium car park and an ambition on the part of the Council is to reinstate the Stadium for Greyhound and Speedway use.

BAP have assessed the noise levels incident on existing dwellings and the proposed residential development due to use of the Stadium.

There are around 30 dwellings on Sandy Lane and 6 dwellings on Greyhound View that will be exposed to significant levels of noise from operation of the Stadium. The noise exposure for the recently built inset dwellings on Greyhound View will be particularly bad. These dwellings were constructed after the closure of the stadium and have no specific noise mitigation measures to protect residents from noise from Stadium use.

The assessment has found that the proposed development will result in the exceedance of recommended noise standards by a substantial margin. It may be feasible to use this site for residential use, but this will require severe noise control measures. The current proposal maximises the separation distance between the stadium and the flats which assists. The development generally avoids noise sensitive habitable rooms on the façades which overlook the stadium. A detailed scheme of noise mitigation will need to be developed to demonstrate compliance with recommended internal noise standards. Noise levels in gardens and external amenity areas will exceed recommended guidelines.

David Trew David Charles for Bickerdike Allen Partners LLP Partner

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The Decibel, dB

The unit used to describe the magnitude of sound is the decibel (dB) and the quantity measured

is the sound pressure level. The decibel scale is logarithmic and it ascribes equal values to APPENDIX 1 proportional changes in sound pressure, which is a characteristic of the ear. Use of a logarithmic scale has the added advantage that it compresses the very wide range of sound pressures to GLOSSARY OF ACOUSTIC TERMINOLOGY which the ear may typically be exposed to a more manageable range of numbers. The threshold of hearing occurs at approximately 0 dB (which corresponds to a reference sound pressure of 2 x 10-5 Pascals) and the threshold of pain is around 120 dB.

The sound energy radiated by a source can also be expressed in decibels. The sound power is

a measure of the total sound energy radiated by a source per second, in watts. The sound power level, L is expressed in decibels, referenced to 10-12 watts. w Frequency, Hz

Frequency is analogous to musical pitch. It depends upon the rate of vibration of the air molecules that transmit the sound and is measure as the number of cycles per second or Hertz (Hz). The human ear is sensitive to sound in the range 20 Hz to 20,000 Hz (20 kHz). For acoustic engineering purposes, the frequency range is normally divided up into discrete bands. The most commonly used bands are octave bands, in which the upper limiting frequency for any band is twice the lower limiting frequency, and one-third octave bands, in which each octave band is divided into three. The bands are described by their centre frequency value and the ranges which are typically used for building acoustics purposes are 63 Hz to 4 kHz (octave bands) and 100 Hz to 3150 Hz (one-third octave bands).

A-weighting

The sensitivity of the ear is frequency dependent. Sound level meters are fitted with a weighting network which approximates to this response and allows sound levels to be expressed as an overall single figure value, in dB(A).

Environmental Noise Descriptors

Where noise levels vary with time, it is necessary to express the results of a measurement over a period of time in statistical terms. Some commonly used descriptors follow.

Statistical Term Description

LAeq, T The most widely applicable unit is the equivalent continuous A- weighted sound pressure level (LAeq, T). It is an energy average and is defined as the level of a notional sound which (over a defined period of time, T) would deliver the same A-weighted sound energy as the actual fluctuating sound.

LA90 The level exceeded for 90% of the time is normally used to describe background noise.

A11246_01_RP005_2.0 Page 13

LAmax,T The maximum A-weighted sound pressure level, normally receiving room below and the result is known as the impact level, Li for laboratory tests and L’i associated with a time weighting, F (fast), or S (slow) for field tests.

Sound Transmission in Rooms

Sound energy is reflected from the room surfaces and this gives rise to reverberation. At short distances from a sound source, the sound level will fall off at a rate of 6 dB per doubling of distance, as it would in the open air – this is known as the direct field. Beyond a certain distance, the effect of reverberation takes over and the level ceases to fall off significantly with distance from the source. This is known as the reverberant field. For receiver positions in this part of the room, sound levels can be reduced by applying sound absorbing finishes to the surfaces of the room. A 3 dB reduction can normally be obtained by doubling the absorption present, which corresponds to halving the reverberation time (see below).

Sound Insulation - Airborne

Voices, hi-fi systems, television and radio sound and musical instruments are all sources of airborne sound. They excite the air around them and the vibration in the air is transmitted to surrounding surfaces, such as walls, ceilings and floors. This sets these constructions into vibration and this vibration is radiated in neighbouring rooms as sound. Energy is lost in the transmission path and this is referred to as transmission loss or, more generally, sound insulation. The most simple measure of sound insulation is the sound level difference, D, which is the arithmetic difference between the sound level, in dB, in the source room and the sound level in the receiving room.

Other measures of sound insulation include the sound reduction index, R, which is a measure of the acoustical performance of a partition, obtained in a laboratory, and the standardised level difference, DnT, which is used mainly in the sound insulation of domestic separating walls and separating floors. The relevant test procedures are laid down in BS EN ISO 140. A single figure “weighted” result can be obtained from one-third octave band test results by using a curve-fitting procedure laid down in BS EN ISO 717. The subscript “w” is added to the relevant descriptor (eg DnT,w).

The sound reduction index, R, is used in the specification of components, such as partitions, doors and windows. It is important to bear in mind that the performance of components in the field is usually lower than can be obtained in a laboratory. The transmission of sound via other components common to both rooms (“flanking transmission”) can reduce the apparent sound reduction index (R’) significantly.

Sound Insulation - Impact

In the case of impact sound, the building construction is caused to vibrate as a result of a physical impact. Footsteps on floors are the most obvious example. The vibration is radiated as sound in neighbouring rooms. Impact insulation is measured using a standard tapping machine, which drops weights cyclically onto a floor. The sound pressure level is measured in the

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APPENDIX 2 OXFORD STADIUM NOISE AND VIBRATION SURVEY

A11246_01_RP005_2.0 Page 15

ENVIRONMENTAL NOISE AND VIBRATION SURVEYS sources on the site itself. The daytime measurements have been supplemented by attended measurements. To assess the existing levels of environmental noise and vibration several surveys were carried out around the site. Measurements were made both in 2013 and 2014. Additional Instrumentation measurements were made in 2014 to measure rail freight to the BMW/Mini factory. These are 2013 presented below, and the measurement positions can be seen below in Figure A2-1. The equipment comprised two Norsonic Class 1 type 118 sound level meters with Norsonic Type 1251 calibrators. The sound level meters were calibrated at the start and end of the survey. No significant drift was observed.

2014

The equipment comprised one Norsonic Class 1 type 118 sound level meter and one Norsonic Class 1 type 140 sound level meter with two Norsonic Type 1251 calibrators. The sound level meters were calibrated at the start and end of the survey. No significant drift was observed.

Methodology

Unmanned measurements were taken at a positions representative of the façade of the block of proposed flats facing the rail line and the bus depot based on an earlier superseded site layout. The microphone was set up on a mast in a free field environment approximately 4m above the ground at positions 1, 2 and 5.

Results

A summary of the 2013 unattended survey results is presented in Table A2-1. Raw data is available on request.

Octave band centre frequency, Hz (dB) Position Noise level 125 250 500 1k 2k 4K A Daytime 1 54 54 52 52 45 41 55 Leq,T (07:00-23:00) Night-time 1 50 44 43 45 36 39 48 Leq,T (23:00-07:00)

Night-time1 Figure A2-1: Noise measurement locations 1 LA,max for train 77 69 68 64 68 71 75 passby Position 1 – Used for long term noise and vibration of rail freight (2014 & 2014) Table A2-1 Results of long-term noise survey, 2013 Position 2 – 2013 Attended ambient noise measurement location 1 During the 2013 noise survey no rail freight passbys were observed. Noise data was taken Position 3 – 2013 Attended Road traffic noise measurement location from comparable site for a typical rail freight passby LAmax. Unattended noise measurements

Unattended measurements were taken between the 20th & 23rd of January 2014. Weather conditions were generally overcast and dry, with light winds, and occasional spells of light rain.

During noise surveys the go-kart track was operational sporadically throughout day-time working hours. The night time noise measurements are likely to be unaffected by any noise

A11246_01_RP005_2.0 Page 16

A summary of the results of the 2014 long term noise surveys is presented below in Table A2- Results 2. Table A2-3 below shows the results for each attended measurement taken on the 7th January 2013 at positions 3 and 4 Octave band centre frequency, Hz (dB) Position Noise level 125 250 500 1k 2k 4K A Noise level dB(A) Position Time Duration Daytime 1 54 53 53 50 43 38 54 LA10 LAeq LA01 LAF,max L , eq T (07:00-23:00) 3 13:00 5:00 64 63 74 89 Night-time 3 13:05 5:00 63 60 71 78 1 47 45 42 43 42 42 49 Leq,T (23:00-07:00) 3 13:10 5:00 65 60 71 76 Night-time 3 13:15 5:00 62 59 68 71 1 LAF,max for train 75 74 66 62 60 59 70 3 13:20 5:00 64 60 70 75 passby 3 Average(1) / / 64 60 71 75 Table A2-2 - Results of 2014 additional measurements 2 13:35 5:00 56 54 57 59 2 13:40 5:00 57 55 63 66 The 2014 noise survey ran over four days. Two rail freight movements were measured during 2 13:45 5:00 55 54 58 62 st nd the night of 21 to 22 January 2014. Both produced noise maxima of 70 dB LAF,max. These two 2 13:50 5:00 55 54 57 59 rail freight passbys correlated with measurements of vibration at the same location. This level 2 13:55 5:00 56 54 59 62 is 5 dB lower than that previously assumed for the 2013 assessment. 2 14:00 5:00 54 53 57 58 2 14:05 5:00 56 54 57 62 The average dB LAeq day and night noise levels at Position 1 (rail line) were almost identical in 2 Average(1) / / 56 54 58 61 2013 and 2014. Table A2-3 - Attended short-term measurement results (positions 2 &3) Attended noise measurements (1) All results arithmetic average except dB LAeq which is a logarithmic average. Attended measurements were taken at locations 3 & 4 on the 7th January 2013 during the middle of the day. Weather conditions were generally clear, with light winds. VIBRATION ASSESSMENT Instrumentation Vibration criteria The equipment for both surveys comprised a Brüel and Kjær 2260 Type 1 sound level meter Vibration created by trains can give rise to two potentially undesirable effects. The first is and a Brüel and Kjær 4231 calibrator. The sound level meter was calibrated at the start and end perceptible vibration. This is vibration physically felt by the body due to contact with vibrating of the surveys. No significant drift was observed. surfaces. The other potentially undesirable effect is that of the sometimes audible noise, or rumble, that is created by the vibration of the surrounding surfaces (walls and floors) within a space.

Guidance on human response to building vibration is given in BS6472: 2008 Evaluation of human exposure to vibration in buildings (1 Hz to 80 Hz). This British Standard does not suggest limits of vibration. However, the standard does provide tentative guidance on the magnitudes of vibration at which adverse comment may begin to arise. These magnitudes of vibration expressed in terms of Vibration Dose Values (VDVs) can be seen below in Table 2.

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Low probability of Adverse comment Adverse comment -1.75 Place Event No. Movements VDV ms BS6472 rating adverse comment possible probable Below “low probability Residential Day Existing Traffic 2 0.01 0.2 – 0.4 0.4 - 0.8 0.8 - 1.6 of adverse comment” 16h day Below “low probability Night Existing Traffic 2 0.01 Residential of adverse comment” 0.1 – 0.2 0.2 – 0.4 0.4 – 0.8 Day Predicted Worst Below “low probability 8h night 6 0.01 Case Traffic of adverse comment” 1.75 Table 2 - Vibration dose values (m/s ) Night Predicted Below “low probability 3 0.01 The relationship between structure-borne noise levels and complaint thresholds has been Worst Case Traffic of adverse comment” studied by London Underground Limited. Data obtained following the opening of the Victoria Table A2-5 VDV Assessment Line in 1969 has been used to establish a complaint threshold of around 40 dB L though it AFmax, is recognised that many people have been exposed to higher levels than this without complaint2.

Noise from structure-borne vibration

For the 2013 an assumed level of vibration was used based on measurements at a comparable site. The 2014 vibration survey measured BMW/Mini rail freight and is presented below.

Third Octave band centre frequency, Hz (dB)

Event 16 20 25 31.5 40 50 63 80 100 125 160 200 250

2013 Assumed 78 77 79 80 75 70 66 67 70 64 60 65 61

2014 measured 66 64 60 63 69 66 73 72 66 61 51 47 50

Table A2-4 Vibration levels

Noise levels of structure-borne noise as a result of train pass-bys have been predicted from the vibration acceleration levels measured from the two observed freight pass-bys measured on site. The predicted noise levels in units nearest the rail line are predicted to be between around

33 dB LAS,max. These are below the maximum 40 dB(A) criterion for reasonable conditions and will only occur up to six times a day. No mitigation measures are necessary.

Perceptible vibration

Vibration Dose Values (VDVs) assessed based on the measured vibration data for the closest dwellings to the track indicate that, during both the daytime and night time, the total VDV will be less than the threshold levels for “a low probability of adverse comment” (0.2ms-1.75 Daytime and 0.1ms-1.75 Night time) according to the tentative guidance in BS6472:2008.

2 Survey of environmental noise and vibration from underground trains services – Proceedings of Internoise 1996. A11246_01_RP005_2.0 Page 18

APPENDIX 3 BELLE VUE NOISE DATA

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Belle Vue Speedway

Noise & Venue Feasibility Assessment

VC-100968-RP001

Rev 00

July 2011

Belle Vue Speedway Noise Management Plan July 2011

Contents

1 Introduction ...... 3

2 The Site and its Environs ...... 4

3 Noise Criteria...... 5

4 Noise Survey ...... 7

5 Background Noise Survey ...... 9

6 Noise Predictions ...... 12

7 Noise Assessment ...... 13

8 Recommendations ...... 14

Appendix A / Glossary of Terms ...... 15

Appendix B / Noise Measurement Locations ...... 16

Appendix C / Background Noise Survey Measurements ...... 17

Vanguardia Consulting Document Control

Document Title: Report Revision: 00 Project Number: VC/100968 Date: July 2011 Document Reference: VC-100968-RP01 Author: Warren King Status: DRAFT Checked: Jim Griffiths Issued To: Populous Passed: Jim Griffiths Issue Notes:

Professional Associations: Institute of Acoustics The Association of Noise Consultants The Audio Engineering Society Institute of Engineering and Technology

Vanguardia Consulting London Office: Southbank Technopark, 90 London Road, London, SE1 6LN Head Office: 21 Station Road West, Oxted, Surrey, RH8 9EE Tel: + 44 (0) 1883 718 690 Fax: + 44 (0) 8700 516 196

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111 Introduction

1.1 Vanguardia Consulting has been commissioned by Populous to provide a noise assessment and venue feasibility study for the proposed construction of a new Speedway stadium at Belle Vue, Manchester.

1.2 The purpose of this document is to provide a feasibility study and initial assessment of the noise impact at residential properties of the proposed relocation of the Belle Vue speedway track from its current location to a new location approximately 300m to the South West. This report is also intended to provide objective guidance for a noise criteria based on national and local planning standards and with reference to noise limits at other motor racing and testing circuits in the United Kingdom.

1.3 The scope of this document is as follows:-

(i) To provide details of the noise levels during a racing event at the venue at the nearest noise sensitive properties to the current venue and those considered to be the nearest noise sensitive properties to the proposed venue. (ii) To provide details of a background noise survey at the nearest noise sensitive properties to the current and proposed venues. (iii) To provide an assessment of the noise impact of the proposed speedway at nearby noise sensitive locations. (iv) To provide a feasibility study for the proposed venue, suggested noise criteria and initial recommendations to assist in the design of the new track.

1.4 It is intended that this document is considered to be a ‘live’ document which it is anticipated will evolve further with ongoing liaison with Manchester City Council.

1.5 A glossary of acoustic terms is shown in Appendix A.

Consultants’ Experience

1.6 Vanguardia Consulting is an acoustic consultancy specialising in the field of sound, noise and acoustics related to entertainment venues. The team of consultants have many years experience dealing with some of the largest and most innovative sound and acoustic projects in the UK, including Wembley Stadium, the Millennium Dome, The Millennium Stadium, Wembley Arena, Earls Court, Silverstone, Darley Moor and Donington Park motor racing circuits and Mercedes Benz World.

1.7 The company directors of Vanguardia have managed Government (DEFRA) research projects related to noise aspects within the sport and leisure industries. As well as the provision of sound and acoustic design / management for the leisure sector, the company deals with a range of acoustic, noise and vibration issues and the consultants have presented expert testimony at planning and licensing hearings, magistrates and high courts, Judicial Reviews and House of Commons and House of Lords Select Committees.

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222 The Site and its EEnvironsnvirons

Belle Vue Stadium

2.1 The Belle Vue Stadium is currently used for greyhound racing, stock car racing and motorcycle speedway. It is proposed that only the motorcycle speedway will be moved to the proposed venue and that the other events will remain at the current stadium.

2.2 Motorcycle speedway racing currently takes place once a week predominantly on Monday evenings and occasional Wednesday evenings between 1930 and 2200hrs from mid march until the end of October. The current planning condition for the stadium allows for racing until 2230hrs.

2.3 Each race consists of four speedway bikes and lasts for approximately 1 minute and 30 seconds (4 laps) with 5 minutes between each race. Each speedway meeting consists of 15 races.

2.4 The nearest noise sensitive locations to the stadium are along Stanley Grove to the South, Kirkmanshulme Lane to the North and the B6716 to the East.

Proposed Speedway Stadium

2.5 The proposed stadium is to be located on the grounds of the Belle Vue leisure centre, approximately 300 metres to the south west of the existing stadium.

2.6 It is proposed that speedway racing will take place on Fridays and occasionally Saturdays at the same time as racing takes place at present.

2.7 It has initially been suggested that there should be no increase in noise levels at noise sensitive locations from the proposed speedway track than experienced from the existing track.

2.8 The nearest noise sensitive locations to the proposed stadium are Stanley Grove and Penketh Avenue to the South of the site, Kirkmanshulme Lane, Scarcroft Road and Ellen Wilkinson Crescent to the North and Pink Bank Lane to the West.

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333 Noise Criteria

3.1 Guidance for assessing and controlling noise from motor racing facilities can be found within the ACU (Auto-Cycle Union) regulations. The regulations specify the measurement procedure that should be adopted and provides the method by which the noise levels should be measured. However, this methodology only provides for the static noise testing of vehicles and does not provide any guarantee against community noise.

3.2 Guidance for the environmental noise impact for motorsport is subject to much discussion and there has been a lack of agreement into the acceptability of noise from motorsport. As a result, there is no recognised noise criteria which deals with noise from racing and testing circuits and a number of different criterion exist for different racing / testing circuits in the UK. A few examples of these are shown in table 1 below:

Table 1: Noise Criteria for racing tracks

Num ber of Days Noise Environmental Noise Location Per Year Restrictions Condition Additional Noise Measures Static noise limit - 105dBA for 3 Noisy Days out 45dBA at 1m from facade of racedays. 4 Trackside noise monitoring Anglesey of a rolling 7 from noise sensitive properties. Unsilenced days equipment. Wind Speed and Circuit 0900-1700hrs or Trackside limit of 77dBA at for Direction logged 10000-1800hrs. 10m from trackside demonstration only Static Limit - Bedford 6 days per week 101 dBA, Drive Noise monitoring equipment Based on track restrictions Autodrome March - December by noise limit at trackside locations 87.5dBA at 20m Static Noise Class 1 vehicles limits - Indy (108dBA) - not 4 quiet days per calendar year circuit 105dBA, restricted .Class 2 during racing season. Use of Grand Prix vehicles (108- track for class 1,2 or 3 vehicles circuit 102dBA. No Planning restrictions 118dBA) - 6 race limited to 0900hrs to 1730hrs Brands Hatch Drive by noise exist. Noise management meetings. Class 3 on testing days. No more than limit of 92dBA. 4 plan vehicles (over two consecutive days of Evening 118dBA) - 6 race testing involving class 3 meetings per meetings per vehicles. week (1730hrs- calendar year 2000hrs). Corporate Enteratinment 0900-1800hrs Mon-Fri and no more than 6 Saturdays per calendar year and 98dB Static / 40dB,LAeq,10min at noise Trackside noise monitoring Bruntingthorpe no more than 50 87.5dB Drive-by sensitive locations equipment times per calendar year. Driver tuition 0900-1900 Mon- Sat. Go-Karts 0900-2100 Mon- Sat Bike trackdays - Cadwell Park Unrestricted 105dBA static test Racedays - Castle Combe 12 Racedays 108dBA 40 days 'noisy Croft activities' Donington 40 days for testing LAmax on quiet days

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Park or racing 7 x 2 day meetings As per ACU East Fortune + 1 Training day Liaison with local residents regulations per year Static Limit - KnockHill Unrestricted 105 dBA for Racedays Static Limit, Category 2 days - 105dB, Category 3 days Category 1 days - - 98dB. Drive by 5 max, Category 2 limits days - 110 max, LAeq,30min. Noise Management Plan. Category 3 days - Category 1 days Bucket' noise limit based on Goodwood Noise monitoring equipment 130 max, Category - unrestricted, external noise levels. at 3 trackside locations 4 days - 71 max, Category 2 days Silent days - 49 - 82dB, min Category 3 days - 78dB, Category 4 days - 70dB (LAeq,5min) Mercedes No restrictions on 5dB above background noise Permanent noise monitor, Benz World Driving Experience level at nearest noise sensitive Liaison with Local Authority (Surrey) Days location and Residents Static limit 105dBA for Bikes or 102dBA if second Bike track day in 7 Trackside noise equipment 30 Racedays (Cars Oulton Park day period. to monitor drive-by noise & Bikes) Quiet day static levels although no limit set limit of 98dBA on Mondays, Thursdays & Sundays Drive by limit - 102dBA daytime, 98dBA Night-time Silverstone No regulated (1700hrs- 0900hrs). Unlimited for some classes

3.3 The UK Motor Sport Association (MSAUK) is currently working on methods to achieve positive control of the environmental impact from motor sport events.

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444 Noise Survey

4.1 An attended noise survey was undertaken on the evening of Wednesday 20 th July 2011 during a speedway meeting.

4.2 The noise monitoring equipment during the survey comprised of a Bruel & Kjaer 2250 type 1 integrating sound level meter positioned at the centre of the circuit to measure and record source noise data from each race and correlate them with measurements made at the noise sensitive locations. A second Bruel & Kjaer 2250 sound level meter was used to measure noise levels at each identified noise sensitive location whilst a race was in progress. The meters were calibrated before and after the survey and no drift in calibration was found.

4.3 A location plan showing the noise measurement locations is shown in Appendix B.

4.4 Table 2, below shows the noise levels at each of the noise sensitive properties during a speedway race.

Table 2: Noise levels at nearest noise sensitive locations during speedway race

Date Time Location Circuit Offsite Difference Current Track Location 20/07/2011 20:02:30 Stanley Grove (Back Gardens) 93.1 77.5 15.6 20/07/2011 20:03:00 Stanley Grove (Back Gardens) 96.2 83.5 12.7 20/07/2011 20:03:30 Stanley Grove (Back Gardens) 96.1 83.4 12.6 20/07/2011 20:04:00 Stanley Grove (Back Gardens) 74.1 66.5 7.7

Race LAeq 94.1 81.0 13.1 Kirkmanshulme Lane (Diamond 20/07/2011 20:11:30 Hotel) 95.3 67.8 27.5 Kirkmanshulme Lane (Diamond 20/07/2011 20:12:00 Hotel) 94.7 68.1 26.6 Kirkmanshulme Lane (Diamond 20/07/2011 20:12:30 Hotel) 83.6 64.8 18.8

Race LAeq 93.4 67.1 26.3

20/07/2011 20:28:30 B6716 (Mountbatten Street) 84.2 62.6 21.5 20/07/2011 20:29:00 B6716 (Mountbatten Street) 96.2 72.9 23.2 20/07/2011 20:29:30 B6716 (Mountbatten Street) 94.7 73.1 21.6 20/07/2011 20:30:00 B6716 (Mountbatten Street) 83.3 67.9 15.3

Race LAeq 92.7 70.8 21.9

Proposed Track Location Stanley Grove (Back Gardens by 20/07/2011 20:47:30 Hockey Pitches) 79.5 52.3 27.2 Stanley Grove (Back Gardens by 20/07/2011 20:48:00 Hockey Pitches) 94.4 61.4 33.0 Stanley Grove (Back Gardens by 20/07/2011 20:48:30 Hockey Pitches) 95.1 63.3 31.9 Stanley Grove (Back Gardens by 20/07/2011 20:49:00 Hockey Pitches) 92.4 61.3 31.1

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Race LAeq 92.9 61.0 31.9

20/07/2011 20:57:00 Penketh Avenue 95.5 59.1 36.4 20/07/2011 20:57:30 Penketh Avenue 94.4 58.3 36.1 20/07/2011 20:58:00 Penketh Avenue 73.9 55.6 18.3

Race LAeq 93.2 57.9 35.3

20/07/2011 21:05:00 Pink Bank Lane 82.1 45.9 36.3 20/07/2011 21:05:30 Pink Bank Lane 95.6 53.7 41.9 20/07/2011 21:06:00 Pink Bank Lane 94.5 53.7 40.9 20/07/2011 21:06:30 Pink Bank Lane 90.2 51.6 38.5

Race LAeq 92.8 52.1 40.7

20/07/2011 21:15:00 Scarcroft Road 79.9 53.1 26.9 20/07/2011 21:15:30 Scarcroft Road 87.6 55.2 32.5 20/07/2011 21:16:00 Scarcroft Road 96.2 58.0 38.2 20/07/2011 21:16:30 Scarcroft Road 95.2 60.1 35.1 20/07/2011 21:17:00 Scarcroft Road 85.8 58.8 27.0

Race LAeq 92.3 57.7 34.7

20/07/2011 21:30:00 Ellen Wilkinson Crescent 94.8 58.1 36.7 20/07/2011 21:30:30 Ellen Wilkinson Crescent 96.4 59.3 37.1 20/07/2011 21:31:00 Ellen Wilkinson Crescent 93.7 58.3 35.4 20/07/2011 21:31:30 Ellen Wilkinson Crescent 73.9 56.9 17.0

Race LAeq 93.8 58.2 35.6

4.5 The noise measurements showed that the typical source LAeq at the centre of the speedway track was approximately 93dB.

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555 Background Noise Survey

5.1 An unattended noise survey was undertaken from Wednesday 20 th July until Sunday 24 th July at two locations to represent the nearest noise sensitive locations to the existing and proposed speedway tracks and to include the days and times of races at the proposed stadium. The noise survey was carried out at the following locations:

The back garden of 311 Stanley Road (Existing Stadium)

The grounds of Belle Vue Leisure Centre to represent noise sensitive properties along Stanley Grove and Penketh Avenue (Proposed Stadium)

5.2 The sound level meter at the leisure centre was located to the South East near the hockey pitches. During the noise measurements recorded on the night of the speedway meeting, a number of hockey matches were taking place on the pitches.

5.3 The noise monitoring equipment during the survey comprised of Larson Davis 812 type 1 integrating sound level meters. The meters were calibrated before and after the survey and no drift in calibration was found.

5.4 Table 3 below shows the free field background noise levels (LA90) and ambient noise levels (LAeq) during typical race times at the monitoring locations during the survey.

Table 3: Free field background and ambient noise levels during typical race times

311 Stanley Grove Leisure Centre Date Time Duration (Existing Track) (Proposed Track) Comments Leq (dBA) L90 (dB) Leq (dBA) L90 (dB) 20Jul 11 19:00:00 900 55 51 56.1 50.2 20Jul 11 19:15:00 900 52.9 49.3 56.4 51.3 20Jul 11 19:30:00 900 54.2 48.2 55.8 50.6 20Jul 11 19:45:00 900 62.4 48 55.7 50.3 20Jul 11 20:00:00 900 69.5 51.2 57 50.2 20Jul 11 20:15:00 900 69 51.3 60.1 50.6 Background noise levels 20Jul 11 20:30:00 900 64.5 49.5 61.2 50.9 measured during 20Jul 11 20:45:00 900 68.3 53.2 56.8 50 speedway 20Jul 11 21:00:00 900 69 50.3 55.9 49.3 meeting 20Jul 11 21:15:00 900 65.7 49.9 54.6 49.2 20Jul 11 21:30:00 900 68.2 49.4 49.3 45.4 20Jul 11 21:45:00 900 64.3 44.1 47.3 43.2 20Jul 11 22:00:00 900 49.4 44.4 45.8 42.4 20Jul 11 22:15:00 900 48.8 41.1 49.3 43

21Jul 11 19:00:00 900 49.2 45.6 53.4 46.3 21Jul 11 19:15:00 900 49.5 45.7 50.2 45.6

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21Jul 11 19:30:00 900 49.9 46.3 48.6 45.7 21Jul 11 19:45:00 900 49.5 46.2 50.3 46 21Jul 11 20:00:00 900 54 47.5 53.5 46.6 21Jul 11 20:15:00 900 51.1 46.8 51.8 46.1 21Jul 11 20:30:00 900 51.7 47.1 50.5 46.1 21Jul 11 20:45:00 900 53.5 46.7 48.5 45.1 21Jul 11 21:00:00 900 54 46.5 50.9 44.7 21Jul 11 21:15:00 900 50.3 45.1 48.3 44 21Jul 11 21:30:00 900 49 44.7 46.7 43.6 21Jul 11 21:45:00 900 48 42.7 46.6 43.2 21Jul 11 22:00:00 900 47.7 43.2 46.1 42.8 21Jul 11 22:15:00 900 48.8 43.5 46.4 42.7 22Jul 11 19:00:00 900 52 46.1 47.1 44.1 22Jul 11 19:15:00 900 50.1 45.9 49.6 44.6 22Jul 11 19:30:00 900 49.9 46.2 47.9 44.6 22Jul 11 19:45:00 900 55.8 47.3 47.9 44.2 22Jul 11 20:00:00 900 57.3 52.1 55.5 47.2 Background 22Jul 11 20:15:00 900 55.5 51.3 55.5 50.4 noise levels 22Jul 11 20:30:00 900 51.4 48.3 48.7 46 measured on evening of 22Jul 11 20:45:00 900 51.3 47 48.5 45 proposed speedway 22Jul 11 21:00:00 900 49.9 46.3 48.6 45.1 meetings 22Jul 11 21:15:00 900 50.2 46.1 48.1 44.4 22Jul 11 21:30:00 900 50.4 46.7 47.7 44.2 22Jul 11 21:45:00 900 50.6 46.3 48.5 44.1 22Jul 11 22:00:00 900 50.4 46.5 48.1 44.2

22Jul 11 22:15:00 900 51.3 46.7 48.6 44.2 23Jul 11 19:00:00 900 52.7 49.4 51.3 47 23Jul 11 19:15:00 900 53.7 49.3 49.3 46.4 23Jul 11 19:30:00 900 57.2 51 49.6 45.9 23Jul 11 19:45:00 900 54.9 50.6 50.6 46.8 23Jul 11 20:00:00 900 54.8 51.1 49.2 46.1 23Jul 11 20:15:00 900 55 51.4 49.6 46.2 23Jul 11 20:30:00 900 55.4 51.1 50.6 46.3 23Jul 11 20:45:00 900 55.5 51.4 50.2 46.1 23Jul 11 21:00:00 900 55.5 51 49.5 45.8 23Jul 11 21:15:00 900 55.3 51.3 50.2 45.5 23Jul 11 21:30:00 900 54.2 51.1 49 46 23Jul 11 21:45:00 900 54.3 50.5 48.6 45.5 23Jul 11 22:00:00 900 53.8 50.2 48.1 44.6 23Jul 11 22:15:00 900 55 49.6 48.5 45.3

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5.5 The full set of monitoring data is shown graphically in Appendix C.

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666 Noise Predictions

6.1 Noise predictions have been calculated at the nearest noise sensitive locations to the proposed speedway track, based on the noise levels measured during a typical speedway race.

6.2 Table 4 below shows the predicted noise levels at the nearest noise sensitive locations to the proposed speedway stadium.

Table 4: Predicted noise levels at nearest noise sensitive locations

Distance Free Field Distance, Location Attenuation, Receiver m dB Level, (dBA) Based on a Race Source Noise Level of 93dB, 25m from Track) Ellen Wilkinson Crescent 135 7.3 85.7 Scarcroft Road 215 9.9 83.1 Pink Bank Lane 275 12.7 80.3 Penketh Avenue 95 5.8 87.2 Stanley Grove (Back Gardens by Hockey Pitches) 140 7.5 85.5

6.3 The predicted noise levels do not take into account any attenuation from barriers from the stadium itself or any other mitigation measures.

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777 Noise Assessment

7.1 Table 5, below shows a summary of the predicted noise levels with no mitigation measures at the nearest noise sensitive locations to the proposed speedway stadium and the noise levels currently experience at those locations from the existing stadium.

Table 5: Assessment of current noise levels and noise levels from proposed stadium at nearest noise sensitive locations

Predicted Measured Required Location Noise Level Noise Level Attenuation (LAeq, dB) (LAeq, dB) Stanley Grove (Back Gardens by Hockey Pitches) 85.5 61.0 24.5 Penketh Avenue 87.2 57.9 29.3 Pink Bank Lane 80.3 52.1 28.2 Scarcroft Road 83.1 57.7 25.4 Ellen Wilkinson Crescent 85.7 58.2 27.5

7.2 The comparison of predicted noise levels from the proposed stadium with the measured noise levels from the existing stadium shows an increase of between 25 and 30 dB during a speedway race at the nearest noise sensitive locations with no noise mitigation measures in place. The noise levels measured at Kirkmanshulme Lane during a race at the existing stadium with the stand acting as an effective noise barrier demonstrates that the suggested noise criteria of no increase in noise levels can be achieved with the consideration of effective noise mitigation measures for the proposed stadium.

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888 ReReRecommendationsRe commendations

8.1 In order to ensure that the suggested noise criteria of no increase in noise levels at noise sensitive locations, it is recommended that noise mitigation measures are considered at the design stage of the new stadium.

8.2 The noise impact of speedway racing may be predicted and assessed with the design of the proposed stadium using IMMI noise modelling software and based on the track noise levels measured during the speedway meeting. The noise contour models would take account of any barriers between the noise source and noise sensitive locations and provide noise contour plots to assess the noise impact of the speedway racing at all community sites surrounding the proposed stadium.

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Appendix A / Glossary of Terms

A.1 Noise is defined as unwanted sound. The range of audible sound is from 0dB to 140dB, which is taken to be the threshold of pain . The sound pressure detected by the human ear covers an extremely wide range. The decibel (dB) is used to condense this range into a manageable scale by taking the logarithm of the ratio of the sound pressure and a reference sound pressure.

A.2 The freque ncy response of the ear is usually taken to be about 18Hz (number of oscillations per second) to 18,000Hz. The ear does not respond equally to different frequencies at the same level. It is more sensitive in the mid -frequency range than at the lower and higher frequencies, and because of this, the low and high frequency component of a sound are reduced in importance by applying a weighting (filtering) circuit to the noise measuring instrument. The weighting which is most used and which correlates best wi th the subjective response to noise is the dB(A) weighting. This is an internationally accepted standard for noise measurements.

A.3 The ear can just distinguish a difference in loudness between two noise sources when there is a 3dB(A) difference between them . Also when two sound sources of the same noise level are combined the resultant level is 3dB(A) higher than the single source. When two sounds differ by 10dB(A) one is said to be twice as loud as the other.

A.4 The subjective response to a noise is depende nt not only upon the sound pressure level and its frequency, but also its intermittency. Various indices have been developed to try and correlate annoyances with the noise level and its fluctuations. The parameter used for this

measure is Equivalent Cont inuous Sound Pressure Level (L Aeq ). The A -weighted sound pressure level of a steady sound that has, over a given period, the same energy as the fluctuating sound under investigation. It is in effect the energy average level over the specified measurement period (T) and is the most widely used indicator for environmental noise. A few examples of noise of various levels are given right:

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Appendix B / Noise Measurement Locations

Kirkmanshulme Lane

Ellen Wilkinson Crescent B6716 Scarcroft Road

Proposed Stadium

Stanley Grove Pink Bank Lane

Stanley Grove Penketh Ave (Hockey Pitches)

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Appendix C / Background Noise Survey Measurements

Noise Measurements at 311 Stanley Grove 20th - 24th July 2011 80 70 60 50 40 Leq L(90) 30 20 15 minute 15 noise levels (dBA) 18:15:00 23:00:00 03:45:00 08:30:00 13:15:00 18:00:00 22:45:00 03:30:00 08:15:00 13:00:00 17:45:00 22:30:00 03:15:00 08:00:00 12:45:00 17:30:00 22:15:00 03:00:00 07:45:00

Noise Measurements at Leisure Centre 20th -24th July 2011 80 70 60 50 40 30 Leq 20 L(90) 10 0 15 minute 15 noise levels (dBA) 18:35:00 23:15:00 04:00:00 08:45:00 13:30:00 18:15:00 23:00:00 03:45:00 08:30:00 13:15:00 18:00:00 22:45:00 03:30:00 08:15:00 13:00:00 17:45:00 22:30:00 03:15:00 08:00:00

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APPENDIX 4 SITTINGBOURNE SPEEDWAY NOISE DATA

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KENT KINGS SPEEDWAY

SITTINGBOURNE, KENT, ME10 3SB

ENVIRONMENTAL NOISE SURVEY

Report to

Phil Clark, Galliard Homes Limited, Sterling House, Langston Road, Loughton, IG10 3TS

A11246_01_RP002_1.0 09 October 2019

Bickerdike Allen Partners LLP is an integrated practice of Architects, Acousticians, and Construction Technologists, celebrating over 50 years of continuous practice.

Architects: Design and project management services which cover all stages of design, from feasibility and planning through to construction on site and completion.

Acoustic Consultants: Expertise in planning and noise, the control of noise and vibration and the sound insulation and acoustic treatment of buildings.

Construction Technology Consultants: Expertise in building cladding, technical appraisals and defect investigation and provision of construction expert witness services.

A11246_01_RP002_1.0 09 October 2019 2

Contents Page No.

1.0 Introduction ...... 4

2.0 Site & Activity Description ...... 4

3.0 Method ...... 6

4.0 Results ...... 7

Appendix 1: Glossary of Acoustic Terminology

Bickerdike Allen Partners LLP hereby grant permission for the use of this report by the client body and its agents in the realisation of the subject development, including submission of the report to the design team, contractor and sub-contractors, relevant building control authority, relevant local planning authority and for publication on its website.

A11246_01_RP002_1.0 09 October 2019 3

1.0 INTRODUCTION

Bickerdike Allen Partners LLP (BAP) have carried out an environmental noise survey of speedway racing at Central Park Stadium, Sittingbourne on 7 October 2019. The purpose of this survey was to observe and measure sound levels from a typical Speedway meeting to provide reference sound data for noise modelling exercises. Measurements have been made both inside the stadium and at a location representative of the nearest dwellings.

A glossary of acoustic terminology used is included in Appendix 1.

2.0 SITE & ACTIVITY DESCRIPTION

This survey was conducted at Central Park Stadium, Sittingbourne, an aerial layout of which can be seen below in Figure 1. The site is in the Eurolink Industrial Estate and is surrounded to the east, north and west by warehouses and other industrial buildings. To the south lies the residential area of Murston, with the closest residential receptors separated by playing fields and situated approximately 170 m from the southern perimeter of the stadium grounds.

Figure 1: Central Park Stadium, Sittingbourne. The residential area of Murston lies to the south and south west. The stadium is otherwise surrounded by the Eurolink Industrial Estate. Measurements were taken at positions P1 and P2.

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The stadium circuit area is recessed approximately 4 m below the surrounding ground level, see Figure 2. A substantial noise barrier of approximately 6 m height lines the southern perimeter of the stadium grounds, see Figure 3.

Figure 2: Central Park Stadium, looking north east.

Figure 3: The southern noise barrier, approximately 6 m high.

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Figure 4: Internal noise monitor position, free field

Speedway meetings last for approximately 2 hours and are typically held during the early evening. In this instance, the meeting was held from 18:30 to 20:30. Each meeting usually consists of 15 heats, with each heat comprising 4 laps. Each heat lasts for up to 90 s and is the dominant source of noise during a meeting. In the time between heats, ancillary activities such as race announcements and music over loudspeakers are additional sources of noise. Speedway is a seasonal sport with little activity occurring during the winter.

3.0 METHOD

Noise measurements were taken inside and outside the stadium at positions marked P1 and P2 on Figure 1. Position P1 was inside the stadium, approximately 45 m from the centreline of the speedway track (the inner track) or approximately 90 m from the centre of the stadium. Measurements were taken at this position for 1 hour, capturing 10 heats. The remainder of the meeting was measured at Position P2 on the north side of Hugh Price Close, approximately 265 m from the centre of the stadium. Both measurement positions were free-field.

The noise monitoring equipment comprised a tripod mounted Norsonic 140 sound level meter at 1.5 m height. This was calibrated prior to and after the survey, with a Norsonic Type 1251 calibrator, with no drift observed. Noise levels were recorded in terms of decibels (dB), using the standard reference value of 20 µPa, and in third-octaves across the frequency range 6.3 Hz to 20 kHz. Noise measurements were set up to measure 15 minute samples with a 1 second resolution.

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The temperature during the survey was between 13-14 degrees Celsius. The humidity was around 90% with light rain. There were southerly winds with a speed of 5-6m/s.

4.0 RESULTS

The results of the noise measurements are presented below. Raw data can be made available on request.

Results for measurements undertaken at position P1 are presented in Table 1: Results for

position P1.Table 1 in terms of LAeq,90s. This represents the energy average noise level measured during the 4 laps of a 90 s heat.

Heat LAeq,90s (dB) 1 85 2 84 3 85 4 84 5 87 6 86 7 87 8 84 9 86 10 86 Average 86 Table 1: Results for position P1.

Over the duration of the whole hour at position P1, the measured noise level was 81 dB LAeq,1h. This includes the noise of ancillary activities such as loudspeaker announcements and music. Noise output during this hour was consistent and this level could be considered representative of the entire meeting. A time history of this measurement can be seen in Figure 5. The heats are clearly discernible as the repeated peaks, with each peak subdivided into four individual peaks.

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100

70 dB(A)

40 18:30 18:35 18:40 18:45 18:50 18:55 19:00 19:05 19:10 19:15 19:20 19:25 Time

LAeq,1s LAFmax,1s LA90,15m

Figure 5: Time history of measurement position P1, inside the stadium.

Results for measurement position P2 are presented in Table 2. It was not possible to measure for a full hour at this position due to the meeting ending shortly before 20:30. Noise levels were again consistent across the 40 minute measurement period. The 40 minute average noise level was 51 dB LAeq,40min. A time history can be seen in Figure 6.

Heat LAeq,90s (dB) 1 53 2 54 3 58 4 55 5 55 Average 55 Table 2: Results for position P2.

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100

Surveyor Surveyor 80

70 dB(A)

40 19:40 19:45 19:50 19:55 20:00 20:05 20:10 20:15 20:20 Time

LAeq LAFmax LA90

Figure 6: Time history of measurement position P2, Hugh Price Close.

Mike Pau David Trew for Bickerdike Allen Partners LLP Partner

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APPENDIX 1 GLOSSARY OF ACOUSTIC TERMINOLOGY

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The Decibel, dB

The unit used to describe the magnitude of sound is the decibel (dB) and the quantity measured is the sound pressure level. The decibel scale is logarithmic and it ascribes equal values to proportional changes in sound pressure, which is a characteristic of the ear. Use of a logarithmic scale has the added advantage that it compresses the very wide range of sound pressures to which the ear may typically be exposed to a more manageable range of numbers. The threshold of hearing occurs at approximately 0 dB (which corresponds to a reference sound pressure of 2 x 10-5 Pascals) and the threshold of pain is around 120 dB.

The sound energy radiated by a source can also be expressed in decibels. The sound power is a measure of the total sound energy radiated by a source per second, in watts. The sound power -12 level, Lw is expressed in decibels, referenced to 10 watts.

Frequency, Hz

A-weighting

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Environmental Noise Descriptors

Where noise levels vary with time, it is necessary to express the results of a measurement over a period of time in statistical terms. Some commonly used descriptors follow.

Statistical Term Description

LA90 The level exceeded for 90% of the time is normally used to describe background noise.

LAmax,T The maximum A-weighted sound pressure level, normally associated with a time weighting, F (fast), or S (slow)

Sound Transmission in Rooms

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Sound Insulation - Airborne

Sound Insulation - Impact

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APPENDIX 5 PETERBOROUGH GREYHOUND NOISE DATA

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PETERBOROUGH GREYHOUNDS

141 FENGATE, PETERBOROUGH, PE1 5XA

ENVIRONMENTAL NOISE SURVEY

Report to

Phil Clark, Galliard Homes Limited, Sterling House, Langston Road, Loughton, IG10 3TS

A11246_01_RP003_1.0 16 October 2019

Bickerdike Allen Partners LLP is an integrated practice of Architects, Acousticians, and Construction Technologists, celebrating over 50 years of continuous practice.

Architects: Design and project management services which cover all stages of design, from feasibility and planning through to construction on site and completion.

Acoustic Consultants: Expertise in planning and noise, the control of noise and vibration and the sound insulation and acoustic treatment of buildings.

Construction Technology Consultants: Expertise in building cladding, technical appraisals and defect investigation and provision of construction expert witness services.

A11246_01_RP003_1.0 16 October 2019 2

Contents Page No.

1.0 Introduction ...... 4

2.0 Site & Activity Description ...... 4

3.0 Method ...... 6

4.0 Results ...... 7

Appendix 1: Glossary of Acoustic Terminology

A11246_01_RP003_1.0 16 October 2019 3

1.0 INTRODUCTION

Bickerdike Allen Partners LLP (BAP) have carried out an environmental noise survey of greyhound racing at Peterborough Stadium on 12 October 2019. The purpose of this survey was to observe and measure sound levels from a typical grehound meeting to provide reference sound data for noise modelling exercises. Measurements have been made both inside the stadium and at a location representative of the nearest dwellings.

A glossary of acoustic terminology used is included in Appendix 1.

2.0 SITE & ACTIVITY DESCRIPTION

This survey was conducted at Peterborough Stadium an aerial layout of which can be seen below in Figure 1. The site is in the predominantly industrial Fengate area of Peterborough. Fengate road provides access to the Stadium and there are some residential properties approximately 130m to the north of the stadium. These dwellings benefit from the incidental noise screening effect of the stadium building which can be seen below above position P1.

There is a large new-build residential development to the west of the stadium. This is known as the “Connect 21” development. These are approximately 250m away from the stadium and do not benefit from any noise screening.

Figure 1: Peterborough Stadium. The residential area Connect 21 lies to the west. This development is now complete and occupied. Measurements were taken at positions P1 and P2.

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The topography of the stadium and surrounding area is flat. The majority of customers use the bars and restaurants inside the stadium building which is enclosed with large glazed windows, see Figure 2. A small number of customers use the external seating area for gambling/spectating/smoking and there is some crowd noise here.

During the survey there was no amplified music outside. There is a PA system with loudpseakers mounted in the roof/awning of the stadium. These are used for intermittent announcements and for race commentary.

Figure 2: Peterborough Stadium, looking west

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Figure 3: Nearby flats overlooking the stadium, Hartley Avenue

Greyound meetings at Peterborugh last for approximately 3 hours and are typically held during the evenings on Wednesdays, Fridays and Saturdays throughout the year.

Each meeting usually consists of 13 races, with each heat comprising 250m or 430m races lasting approximately 15 and 30 seconds respectively. The races are scheduled very 15 minutes. Immediately before and after each race there are announcements on the PA system. There are periods of around 10 minutes between each race where there are few, if any, PA announcements. There is some cheering from the crowd during the race. However as most customers are inside the stdium building these levels are modest.

3.0 METHOD

Noise measurements were taken inside and outside the stadium at positions marked P1 and P2 on Figure 1. Position P1 was inside the stadium near the external seating/smoking area and therefore a worst-case measurement location. This position was also close to one of the PA loudspeakers and within the crowd area approximately 1m from a wall, a façade measurement location.

Measurements were taken at this position for approximately 1 hour, capturing 5 races. Further measurements and observations were made at Hartley Avenue Position P2 approximately 250 m from the stadium. This was a free-field measurement position.

The noise monitoring equipment comprised a Norsonic 140 sound level meter at 1.5 m height. This was calibrated prior to and after the survey, with a Norsonic Type 1251 calibrator, with no

A11246_01_RP003_1.0 16 October 2019 6

drift observed. Noise levels were recorded in terms of decibels (dB), using the standard reference value of 20 µPa, and in third-octaves across the frequency range 6.3 Hz to 20 kHz. Noise measurements were set up to measure 15 minute samples with a 1 second resolution.

The temperature during the survey was between 12 degrees Celsius. The humidity was around 90% with no rain. There were southerly winds with a speed of 3m/s.

4.0 RESULTS

The results of the noise measurements are presented below. Raw data can be made available on request.

Results for measurements undertaken at position P1 are presented in Table 1 below.

Time Duration LAeq,T (dB) 19:11 4mins 74 19:15 15 mins 76 19:30 15 mins 79 19:45 15 mins 79 20:00 15 mins 79 20:15 15 mins 81 20:30 4 mins 82 Average 79 Table 1: Results for position P1.

Over the duration of the whole hour at position P1, the measured noise level was 79 dB LAeq,1h. This was dominated by the noise of loudspeaker announcements and some crowd noise. Noise output during this hour was consistent and this level could be considered representative of the entire meeting. A time history of this measurement can be seen in Figure 4.

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Figure 4: Time history of measurement position P1, inside the stadium.

Results for measurement position P2 are presented in Table 2.. Noise levels were again consistent across the measurement period. The 60 minute average noise level was

44 dB LAeq,40min. A time history can be seen in Figure 5.

The background sound level was low at around 41 dB LA90 and was dominated by distant traffic noise on the A1139. Noise from the PA system was audible and measureable. This can not be seen in the 15 minute data but can be seen from the time histories as peaks of noise between 45 and 50 dB(A).

The measured data both on and off site suggests that the noise from the greyhound racing can be simplified as either a single or multiple point sources producing noise levels of around 79- 84 dB (A) at around 5 m. The point sources would need to be representative (for modelling purposes) of PA speakers and external crowd locations.

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Start time Duration LAeq,T LA90,T 20:45 15 mins 45 42 21:00 15 mins 44 41 21:15 15 mins 44 42 21:30 15 mins 45 42 Average 44 41 Table 2: Results for position P2.

Figure 5: Time history of measurement position P2

Mike Pau David Trew for Bickerdike Allen Partners LLP Partner

A11246_01_RP003_1.0 16 October 2019 9

APPENDIX 1 GLOSSARY OF ACOUSTIC TERMINOLOGY

A11246_01_RP003_1.0 16 October 2019 10

The Decibel, dB

Frequency, Hz

A-weighting

A11246_01_RP003_1.0 16 October 2019 11

Environmental Noise Descriptors

Where noise levels vary with time, it is necessary to express the results of a measurement over a period of time in statistical terms. Some commonly used descriptors follow.

Statistical Term Description

LA90 The level exceeded for 90% of the time is normally used to describe background noise.

LAmax,T The maximum A-weighted sound pressure level, normally associated with a time weighting, F (fast), or S (slow)

Sound Transmission in Rooms

A11246_01_RP003_1.0 16 October 2019 12

Sound Insulation - Airborne

Sound Insulation - Impact

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Oxford Greyhound Stadium

Lighting Assessment and Results

Cowley Investments Limited

Job No: 1025003

Doc Ref: 1025003-RPT-LG-002

Revision: B

Revision Date: 08 November 2019

Project title Oxford Greyhound Stadium Job Number

Report title Lighting Assessment and Results 1025003

Document Revision History

Revision Ref Issue Date Purpose of issue / description of revision

— 30/10/2019 For Information

A 07/11/2019 Final Issue

B 08/11/2019 Final Issue

Document Validation (latest issue)

X X X Hannah Murphy Checked by Verified by Lighting Designer

© Cundall Johnston & Partners LLP (“Cundall”) owns the copyright in this report and it has been written for the sole and confidential use of Cowley Investments Limited. It must not be reproduced whole or in part without the express written authorisation of Cundall Johnston & Partners LLP. Parties other than those specifically named in this disclaimer must not rely upon this report. Any third party relying on this report does so at their own risk. Cundall accepts no duty or responsibility (including in negligence) to any such third party.

Document Ref. 1025003-RPT-LG-002 Template version 1.0 – 23 July 2017

Executive Summary

Galliard Homes are proposing to redevelop the Oxford Greyhound Stadium located on Sandy Lane, close to Cowley South East of Oxford. The plans to redevelop include the strategy of televising the dog racing which would require additional lighting for television broadcaster standards. A proposed lighting design has been calculated by Cundall Light4 to assess the lighting requirements for TV broadcasting and analyse the light pollution produced from the upgraded design.

Contents

1.0 Introduction 4

2.0 Policy Context 6

2.1 Industry Standards 6 2.2 Sports and Television Broadcasting Standards 6

3.0 Developed Lighting Design 10

3.1 Strategy 10 3.2 Light Pollution Criteria 10 3.3 Light Pollution Results 10 3.4 Light Pollution Conclusion 12

4.0 Final Conclusion 14

1.0 Introduction

Cundall Light4 were commissioned by Galliard Homes to undertake a site assessment of the Oxford Greyhound Stadium. Following the on-site assessment and determination that the existing lighting needs to be replaced and updated, a lighting design was developed and calculated in line with the correct TV broadcasting standards. The results were then analysed to determine the light spill, source glare and sky glow, looking specifically at the West carpark.

2.0 Policy Context

2.1 Industry Standards

2.1.1 Institute of Lighting Professionals. Guidance note on the reduction of obtrusive light, (GN01:2011)

• The ILP Guidance note sets out the industry standard for numerically measuring, (both through lighting design calculations and on site), the light spill from lighting into windows, sky glow, source luminance and building façade brightness. The ILP guidance note provides illuminance, luminance and percentage figures which must be satisfied both pre-and post curfew for various types of environmental zone classifications. See tables 1 and 2 below.

Table 1 - Environmental Zones for Obtrusive Lighting Limitations for Exterior Lighting Installations

Table 2 - Obtrusive Lighting Limitations for Exterior Lighting Installations

• The Oxford Greyhound Stadium site is situated South East of Oxford centre near Cowley. It is within a suburban area which allows it to meet with the E3 ‘Suburban’ classification of area.

2.2 Sports and Television Broadcasting Standards

2.2.1 Lighting Guide 4 – Sports Lighting (October 2006)

• Chapter 2.2 Illuminance requirements states the lighting classes based on the level of sport competition/participation which then determines the recommend minimum illuminance level.

• Addendum 7a Lighting for television has currently replaced Chapter 7. • Addendum 7a.2.1 Vertical illumiance states the illuminance on a vertical plane perpendicular to the camera direction forms the basis of the lighting requirements for TV and film systems. • Addendum 7a.2.2 Horizontal illuminance states that the ratio between the average horizontal iluminance and the average vertical illuminance (relative to the main cameras) will influence the quality of the picture contract. • Addendum 7a.2.4 Colour temperature of the lighting states that the colour temperature of the artificial lighting shall be between 5000K and 6000K.

2.2.2 CIE Technical Report – Guide for the lighting of sport events for colour televisions and film systems. CIE 83-1989

• Chapter 2 Requirements for lighting states the vertical illuminance is the most suitable measure for assessing the adequecy of lighting • Chapter 2.2.1 Speed of action states that dog, horse and motor racing would be classed asa medium speed. This is terms of movement along the track. • Chapter 2.2.3 Classes of sport discusses the divison of sports into three categories and the maximum shooting distance. • Dog racing is classed as Group B, medium speed and the recommended illuminance levels can be viewed in Table 3.

Table 3 – Minimum illuminance levels required for maximum shooting distances

• Chapter 2.6 Reduction of flicker states that light flicker should be minimised, so that when shooting with film or TV cameras, interference will be as low as possible. • Chapter 2.10 Glare states that it is essential that the lighting does not produce an unacceptable degree of glare either to players/competitors, spectators or officials.

2.2.3 CIE Technical Report – Practical design guidelines for the lighting of sports events for colour. CIE 169- 2005

• Chapter 2 General design considerations states that a maintenance factor should be included to compensate for ageing and soiling of the lamps, reflectors and front glasses. • Chapter 18 Dog racing provides advice regarding the camera positions and lighting recommendations

2.2.4 BS EN 12193:2018 Light and lighting – sports lighting

• Chapter 7.3.1 General states that the levels of vertical illuminance depend mainly upon the speed of action, the shooting distance, the lens angle and the shutter speed of the camera. • Chapter 7.3.7 Position of floodlights states that for cameras aimed at the playing area, flare can be minimized by ensuring floodlights are not placed in direct view of them. See table 4.

Table 4 - Requirements for floodlight angles

2.2.5 Institute of Lighting Professionals. Guidance for lighting of televised sporting events (February 2018)

• The guidance notes discusses the various measurements required for vertical illuminance, uniformity, aiming angles and glare, colour quality and light flicker. • The guidance states that light intrusion (into windows) value’s are suggested maxima and need to take account of existing light intrusion at the point of measurement. • The guidance states that luminaire intensity applies to each luminaire in the potentially obtrusive direction, outside of the area being lit.

3.0 Developed Lighting Design

3.1 Strategy

• A lighting scheme has been designed and a lighting calculation has been completed for the site to assess the requirement of lighting to pass the TV broadcasting requirements. The lighting scheme follows each of the planning and guidance documents in Chapter 4.

• The lighting scheme has been developed utilising primarily LED floodlights, with a small number of linear LED’s for general illumination as per the existing scheme.

• Whilst the current locations of the TV cameras have not been confirmed, 1400 lux is required on the track to provide substantial illuminance from all angles of the track towards all angles of the track.

• For the lighting directly around the racetrack, additional lighting is required for the recommended illuminance levels. On the existing columns, multiple floodlight heads have been added as per drawings 1025003- BS(63)4002-Proposed Lighting Lux Levels.

• Additional columns have also been included to the North of the edge of the racetrack. These additional fittings provide the required illumination levels and whilst also maintaining the required uniformity.

• A complete uplift of the existing lighting would need to allow for the use of LED floodlights and surface mounted linear’s as replacement lighting. The aim would be to utilise the existing columns on site however due to the requirement for additional floodlights and considering the combined weight, an allowance has been made for new columns. Therefore the total cost for the proposed lighting and columns only is ~£400,000 excludng installation, cabling or workmanship costs.

3.2 Light Pollution Criteria

• Oxford Stadium has been classed as an E3 Environmental Zone within the ILP Guidance Notes of the Reduction of Obtrusive Light, therefore the following standards must be met; • Sky Glow (ULR) – 5.0% • Light Trespass (Lux) – 10 (pre-curfew), 2 (post-curfew) • Source Intensity (cd) – 10,000 (pre-curfew), 1,000 (post-curfew) • Building Luminance (cd/m²) – 10

3.3 Light Pollution Results

• Light trespass and source intensity calculations were completed to pass the ILP guidance notes. A set of receptors were chosen within the West carpark as this is currently a location of concern. The receptors points are highlighted in Figure 1. The full results of the calculation can be found in drawing 1025003-BS(63)4002- Proposed Lighting Lux Levels, however the results are surpassing the guidance note recommendations which will have a negative impact on the surrounding area.

Figure 1 – light spill and light trespass calculation points

• Table 5 displays the results from the lighting calculation in line with the ILP guidance notes for the reduction of obtrusive light. The site has been classified as an Environmental Zone E3, with the results shown alongside the requirements. The requirements of the ILP for each Environmental Zone provides recommendation of what is deigned ‘reasonable’.

• The table demonstrates how each light spill and light trespass calculation point surpasses the requirement from the ILP.

• The table demonstrates how calculation points 4 and 5, which demonstrate the levels at the centre and at the far side of the proposed flats respectively, are also surpassing the ILP guidelines despite the distance from the stadium. The upgraded lighting system would have a negative effect on the proposed new build flats.

• We expect that the upgraded stadium lighting would also have a negative effect on the existing housing adjacent to the stadium on Sandy Lane, with a higher level of illuminance reaching further than the existing lighting.

Table 5 – lighting calculation results against the ILP guidelines

3.4 Light Pollution Conclusion

• The lux level plot drawing 1025003-BS(63)4002-Proposed Lighting Lux Levels, demonstrates the quantity of light spill from the proposed lighting strategy through the use of isolines.

• According to the ILP guidance, the proposed strategy fails each of the recommended observations on the new flat development.

• The light spill spreads further through the car park and onto the proposed flats, and also onto the existing adjacent housing on Sandy Lane than the existing lighting strategy, the implications of the results will cause a negative effect to the area.

4.0 Final Conclusion

• Cundall Light4 have developed and calculated a lighting scheme following plans to upgrade the Oxford Greyhound Stadium to TV broadcasting standards.

• All of the existing lighting is to be replaced on a like for like basis with additional floodlights required for some areas.

• The lighting requirements for the TV broadcasting have been adhered to.

• The developed lighting design exceeds the recommendations for the light spill, source glare and sky glow of the ILP guidelines.

• Cundall Light4 can conclude that upgrading the lighting at the Oxford Greyhound Stadium to the TV broadcasting requirements will be detrimental on the surrounding areas.

Click down arrow to select CUNDALL Entity 10th Floor Manchester One Portland Street Manchester M1 3LD United Kingdom Tel:+44 (0)161 244 5660 Asia Australia Europe MENA UK and Ireland www.cundall.com

Agenda Item 9

To: Cabinet Date: 13 November 2019 Report of: Head of Planning Services Title of Report: Oxford Stadium Summary and recommendations Purpose of report: To put in place a mechanism for this council to assist in bringing forward the Oxford Local Plan 2036 proposals for Oxford Stadium if the policy approach to retain the stadium is supported by the Planning Inspector examining the Local Plan. Key decision: Yes Executive Board Councillor Alex Hollingsworth, Cabinet Member for Member: Planning & Sustainable Transport Corporate Priority: Strong and Active Communities; Meeting Housing Needs; A Vibrant and Sustainable Economy; A Clean and Green Oxford Recommendations: That Cabinet resolves (subject to the Local Plan policy for Oxford Stadium (SP52) to retain the Stadium with enabling residential development being found sound by the appointed Planning Inspector,) to: 1. Seek to procure a development partner / operator, with a viable business plan, to try to acquire the Oxford Stadium by agreement and deliver the requirements set out in Policy SP52 but to indemnify the Council for the associated costs; and, 2. Confirm that if the Oxford Stadium cannot be acquired by agreement, then, as a last resort it would be willing, if necessary, to use its Compulsory Purchase Order (CPO) powers to acquire the site; and to 3. Note that if an option to use CPO powers was to be pursued a further report would need to be submitted to Cabinet to seek approval for a detailed scheme for the redevelopment of this site demonstrating that the legal and policy tests for the use of its CPO powers had been satisfied. This would need to be accompanied by a recommendation to Council to seek authority to set up a budget for any additional costs for the implementation of its CPO powers, which would be redeemed from the development partner. Appendices Appendix 1: Policy SP52: Oxford Stadium

. 11

Introduction 1. the Local Plan policy approach is deliverable and commitment to helping, if necessary, to deliver the proposed development for the revival of greyhound and speedway racing together with supporting leisure and community uses as set out in Policy SP52 for the Oxford Stadium in the Local Plan, if the Planning Inspectors support this allocation at the Examination. 2. The Council has a long-standing policy approach to protect and support sports and leisure uses in Oxford, which on this site has however been balanced against the need for housing within the city. Policy SP52 in the Local Plan reflects this view by supporting leisure / community uses, but allowin

3. If Policy SP52 is supported, the City Council would hope and expect the landowner itself to bring forward the development of this site in accordance with the uses proposed in Policy SP52. However, if a policy compliant development is not forthcoming from the landowner within a timely period then approval is sought from Cabinet to take on a facilitating role in bringing the site forward. 4. In order to do that, approval is sought from Cabinet that in the circumstances that the site is not being brought forward by the landowner in line with the policy requirements the council would seek to procure a development partner / operator, with a viable business plan, to acquire the Oxford Stadium by agreement. In addition approval is sought to confirm that if necessary and as a last resort, in the event that the site cannot be acquired by agreement, the council would be willing to use their powers under a Compulsory Purchase Order (CPO) if satisfied that the legal and policy tests were met. If CPO powers were needed, a further report would need to be submitted to Cabinet for approval which demonstrate the details of the redevelopment scheme and that the relevant legal and policy tests for the use of CPO powers are met, having regard to the circumstances as they exist at that time together with a recommendation to Council for the setting up of a budget for any additional costs for the implementation of its CPO powers, which would be redeemed from the development partner.

Local Plan Allocation and process 5. The Oxford Local Plan 2036 has been submitted to the Secretary of State for Examination. The Inspectors have now been appointed to assess independently policies in the plan and to 6. Policy SP52 allocates the Oxford Stadium site for the revival of greyhound and or speedway racing with supporting community and or leisure uses. Some residential development is proposed as enabling development (assumed to be around 100 homes) to contribute towards the viability of the scheme, providing this respects the operation or historic interest of the site and is consistent with the preservation and enhancement of the Stadium. This was based on March 2018 evidence which suggested that this scheme would be viable. 7. An objection to Policy SP52 has been received from the owner of the site, Cowley Investment Properties. Their principal objections include the lack of consultation with them, as owners, their view that to reopen the stadium is not viable based on a feasibility study they have undertaken that concludes that greyhound stadiums are

no longer viable and the significant investment identified as necessary by them to address the poor state of repair that the stadium is currently in. 8. The Planning Inspectors will consider the C evidence and that submitted by the site owner alongside representations from Sport England and others in support of the Local Plan policy. They will then reach a conclusion as to whether the Local Plan policy for this site is sound and can be kept as currently drafted for adoption. The proposals in this report relate to the policy as submitted for examination. 9. The recommendations for approval would only be pursued if the policy is found sound by the Planning Inspectors following the examination and the plan is adopted by the Council. If the Inspectors materially change the policy so that the stadium is not to be retained then the Council would not implement this course of action as it would no longer be relevant.

Appoint development partner / operator 10. If Policy SP52 is supported, the City Council would hope and expect the landowner to bring forward the development of this site in accordance with the uses proposed in Policy SP52. However, if a policy compliant development is not forthcoming from the landowner within a timely period then approval is sought from Cabinet to take on a facilitating role in bringing the site forward. In these circumstances officers are seeking confirmation that Cabinet will support a resolution to Council to seek a development partner / operator with a realistic and viable business plan to try and acquire the site by agreement and deliver the requirements set out in the submitted policy, but to ensure that the financial implications for the Council are limited.

11. In the first instance, the Council would seek, with its development partner, to acquire the land by agreement. However, recommendation 2 makes it clear that if it is not possible to secure the site by agreement, the Council would as a last resort and if necessary be prepared to use its Compulsory Purchase Order (CPO) powers and seek approval from Council for any associated budgetary expenditure to acquire the site. Any costs incurred by the Council would be expected to be covered by the development partner / operator through a development agreement.

Compulsory purchase process 12. The Council considers that in the event of no agreement being achieved with the landowner that the option to use its CPO powers to help assemble the land would, as a last resort, be pursued. The power to make a CPO which would be relied upon is s.226 of the Town and Country Planning Act 1990. This powers can be relied on inter alia where acquisition is required for a purpose which it is necessary to achieve in the interests of the proper planning of an area in which the land is situated. Section 226 of the Town and Country Planning Act 1990 provides the powers for a local authority to seek the compulsory acquisition of land, subject to the authorisation of the Secretary of State. It is considered that given the deteriorating condition of the property and its location within a Conservation Area it is expedient to pursue the CPO of the site in the interests of the proper planning of the area, which in this case is balanced against the impact on the human rights of those with an interest in the land affected.

13. The CPO process requires the local authority to fully justify the use of CPO powers. There are several legal and policy tests which must be shown to be met. These for use of such powers, as well as in respect of the use of CPO powers. There is a requirement to show that adequate resources are available to implement the scheme within a reasonable time period and that there are no likely impediments to the delivery of the scheme. It is necessary to show that there is no alternative means by which the same purposes could be achieved Recommendation 3 makes it clear that before CPO powers are formally engaged, that a further report would be presented to Cabinet to demonstrate that the relevant legal and policy tests for a CPO were met. Environmental Impact 14. This proposal forms part of Policy SP52 of the draft Oxford Local Plan 2036. This site was assessed as part of the Sustainability Appraisal (which includes a Strategic Environmental Assessment) as submitted to the Secretary of State as part of the supporting evidence for the Oxford Local Plan 2036. Legal Issues 15. Through recommendation 2 approval is sought from Cabinet to confirm a willingness to, if necessary, and as a last resort, use its Compulsory Purchase Order (CPO) powers to acquire the site with the appointed development partner. The development partner / operator would be required, as part of the agreement, to indemnify the Council for any cost/ liability associated with the use of these CPO powers. 16. Before any CPO process is instigated, a further report would need to be submitted to Cabinet to set out the details of the proposals and that the relevant legal and policy tests are met on the a basis of the circumstances as they exist at that time, together with a recommendation to Council to seek approval for a budget for any additional costs for the implementation of its CPO powers, which would be redeemed from the development partner. Financial Implications 17. A further report would be submitted to Cabinet with a recommendation to Council to seek authority to seek approval for a budget for any additional costs for the implementation of its CPO powers, which would be redeemed from the development partner. Equalities Impact 18. Consideration has been given to the public sector equality duty imposed by s149 of the Equality Act 2010. The Council considers there is a need for this development to revive the stadium for greyhound and or speedway, together with other community or leisure uses . This need has been balanced against the public sector equality duty and the impact on human rights but consider that this recommendation for approval to use CPO powers as a last resort is justified, in order to take forward this development scheme. Having paid due regard to the need to meet the objectives of that duty the view is taken that the duty is met.

Report author: Carolyn Ploszynski Planning Policy and Place Manager Planning Services Telephone: 07483012483 e-mail: [email protected]

Background Papers: None

15 Accomodation Summary

52 Unit Option Floor A 3 Accomodation Percentage Breakdown 1 bed 0 0 1 bed 5 17 33% 2 bed 4 12 2 bed 6 20 38% 3 bed 2 6 3 bed 4 12 23% 4 bed 1 3 4 bed 1 3 6% TOTAL 7 21 52 100%

Floor B 3 1 bed 5 15 7 Storeys 2 bed 2 6 Ground floor 4 1 4 3 bed 2 6 Floor A 7 3 21 4 bed 0 0 Floor B 9 3 27 Total 9 27 7 52

100 Unit Option Floor A 6 Accomdation Percentage Breakdown 1 bed 0 0 1 bed 5 32 32% 2 bed 4 24 2 bed 6 38 38% 3 bed 2 12 3 bed 4 24 24% 4 bed 1 6 4 bed 1 6 6% Total 7 42 100 100%

Floor B 6 1 bed 5 30 13 Storeys 2 bed 2 12 Ground floor 4 1 4 3 bed 2 12 Floor A 7 6 42 4 bed 0 0 Floor B 9 6 54 Total 9 54 13 100

Ground floor 1 bed 2 2 2 Bed 2 2 Total 4 4

Parking Courtyard 20 Undercroft 14 Total 34

Acommodation Schedule: Groundfloor

Area (M SQ) No. TOTAL (M SQ)

Gross Plan Area 813.3 813.3 Undercroft Parking 268.9 268.9

One Bed Units Unit 1a 51 1 51 Unit 1b 52 1 52

Two Bed Units Unit 2 a 65 1 65 Unit 2 b 65 1 65

Accomodation Net Total 4 233

Acommodation Schedule: Floor Plan A

Area (M SQ) No. TOTAL (M SQ)

Gross Plan Area 813.3 813.3

Two Bed Units Unit 2 c 77 3 231 Unit 2 d 89.6 1 89.6

Three Bed Units Unit 3 a 101 1 101 Unit 3 b 89 1 89

Four Bed Units Unit 4 a 134 1 134

Accomodation Net Total 7 644.6

Notes: 52 Unit Option X 3 100 Unit Option X 6

Acommodation Schedule: Floor Plan B

Area (M SQ) No. TOTAL (M SQ)

Gross Plan Area 813.3 813.3

One Bed Units Unit 1 a 51 4 204 Unit 1 c 59 1 59

Two Bed Units Unit 2 c 77 2 154

Three Bed Units Unit 3 c 119 1 119 Unit 3 d 101 1 101

Accomodation Net Total 9 637

Notes: 52 Unit Option X 3 100 Unit Option X 6

Oxford Stadium drawing no. SK1 drawing Schematic Sketch Plan N revision drawn by -CM job no. RGPL358363 Galliard scale -1:500 checked by date November 2019 Reproduced from the Ordnance Survey Map with the permission of the Controller of H.M. Stationery Office Crown copyright licence number 100024244 Savills (UK) Ltd. Published for the purposes of identification only and although believed to be correct accuracy is not guaranteed. C:\Users\clare.mitchell\Box\UK Urban Design Projects\UK Oxford Urban Design Projects\RG00000_Oxford Greyhound Stadium\B) Drawings\INDD\RGL358363_Issued 07/11/19 URBAN DESIGN © Copyright Savills (UK) Ltd. Oxford Stadium drawing no. SK2 drawing Schematic Site Layout N revision drawn by -CM job no. RGPL358363 Galliard scale -1:250 checked by date November 2019 Reproduced from the Ordnance Survey Map with the permission of the Controller of H.M. Stationery Office Crown copyright licence number 100024244 Savills (UK) Ltd. Published for the purposes of identification only and although believed to be correct accuracy is not guaranteed. C:\Users\clare.mitchell\Box\UK Urban Design Projects\UK Oxford Urban Design Projects\RG00000_Oxford Greyhound Stadium\B) Drawings\INDD\RGL358363_Issued 07/11/19 URBAN DESIGN © Copyright Savills (UK) Ltd. 2 bed unit

Undercroft parking 5 spaces

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2 bed unit Undercroft Bins parking Bins 3 spaces Undercroft 1 bed unit parking Drive 6 spaces through to 1 bed unit courtyard

Bins Bins Bike storage

Oxford Stadium drawing no. SK3 drawing Ground Floor Plan N revision - drawn by -CM job no. RGPL358363 Galliard scale -1:200 checked by date November 2019 Reproduced from the Ordnance Survey Map with the permission of the Controller of H.M. Stationery Office Crown copyright licence number 100024244 Savills (UK) Ltd. Published for the purposes of identification only and although believed to be correct accuracy is not guaranteed. C:\Users\clare.mitchell\Box\UK Urban Design Projects\UK Oxford Urban Design Projects\RG00000_Oxford Greyhound Stadium\B) Drawings\INDD\RGL358363_Issued 07/11/19 URBAN DESIGN © Copyright Savills (UK) Ltd. Floor Plan A

52 Unit Scheme

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- 3rd Floor

- 5th Floor

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100 Unit Scheme

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- 5th Floor 3 bed unit - 7th Floor

- 9th Floor

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2 bed unit 2 bed unit 2 bed unit 2 bed unit

4 bed unit

Oxford Stadium drawing no. SK4 drawing Floor Plan A N revision - drawn by -CM job no. RGPL358363 Galliard scale -1:200 checked by date November 2019 Reproduced from the Ordnance Survey Map with the permission of the Controller of H.M. Stationery Office Crown copyright licence number 100024244 Savills (UK) Ltd. Published for the purposes of identification only and although believed to be correct accuracy is not guaranteed. C:\Users\clare.mitchell\Box\UK Urban Design Projects\UK Oxford Urban Design Projects\RG00000_Oxford Greyhound Stadium\B) Drawings\INDD\RGL358363_Issued 07/11/19 URBAN DESIGN © Copyright Savills (UK) Ltd. Floor Plan B

52 Unit Scheme

- 2nd Floor

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100 Unit Scheme

- 2nd Floor

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3 bed unit - 8th Floor

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1 bed unit

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1 bed unit 1 bed unit 1 bed unit 1 bed unit

Oxford Stadium drawing no. SK5 drawing Floor Plan B N revision - drawn by -CM job no. RGPL358363 Galliard scale -1:200 checked by date November 2019 Reproduced from the Ordnance Survey Map with the permission of the Controller of H.M. Stationery Office Crown copyright licence number 100024244 Savills (UK) Ltd. Published for the purposes of identification only and although believed to be correct accuracy is not guaranteed. C:\Users\clare.mitchell\Box\UK Urban Design Projects\UK Oxford Urban Design Projects\RG00000_Oxford Greyhound Stadium\B) Drawings\INDD\RGL358363_Issued 07/11/19 URBAN DESIGN © Copyright Savills (UK) Ltd.

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OXFORD STADIUM

Oxford Local Plan 2036

Assessment of the Trading Potential of the Oxford Stadium

Response to Oxford City Council Replies to Inspectors’ Questions

A Report for Cowley Investments Limited October 2019

Cowley Investments Ltd Oxford Stadium November 2019 0

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CONTENTS

INTRODUCTION Page 1

SCOPE OF THIS REPORT Page 1

KEY VIABILITY CONSIDERATIONS Page 2

THE FIVE LINES CONSULTING REPORT Page 6

CONCLUSIONS Page 11

APPENDIX: JOHN ASHWORTH ASSOCIATES Page 12

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INTRODUCTION

1. We have been commissioned by Cowley Investments Limited to respond to the answers given by Oxford City Council to the questions raised by the Local Plan Inspectors on Policy SP52 of the Oxford Local Plan 2036. This report supplements our earlier report dated December 2018.

2. The Inspectors asked: Can the Council point to a detailed and up-to-date viability assessment to demonstrate that development in accordance with these policy requirements would be viable and whether it would be likely to be delivered? Can the Council provide sound and up-to-date evidence to demonstrate that the revival of greyhound racing and/or speedway is a viable and attractive proposition for operators and site owners? Given the considerable housing need in Oxford, would the approach taken by this policy deliver enough homes?

3. The Council responded by reference to a ‘report for the Oxford Stadium – Stage 1 Commercial Viability Assessment, which was prepared by Five Lines Consulting … published on 26th March 2018 and represents the most up to date assessment undertaken on behalf of the City Council’.

4. The Five Lines Consulting report contained ‘an initial assessment of possible profit and loss performance [which] suggests the site could generate an operating profit as a site for greyhound and speedway racing, (this was originally set out in a confidential letter given the commercial sensitivity but is attached as an Appendix 1)’.

5. We responded to the main Five Lines Consulting report in our earlier report of December 2018. This report responds to the Appendix.

SCOPE OF THIS REPORT

6. As agreed with our client, we will not deal with the development appraisal for the housing site set out in the Five Lines appendix; nor with the estimated CPO acquisition cost; nor with the stadium refurbishment costs other than to refer to the findings of other consultants with the expertise more suited to deal with them.

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7. Further, we have agreed to focus on sufficient key points in the Five Lines report appendix rather than to undertake a comprehensive review.

KEY VIABILITY CONSIDERATIONS

8. Demand for greyhound racing primarily comes from the betting industry. Tracks receive revenues from betting companies and the media companies that transmit broadcasts from the tracks. Betting companies and media broadcasters have become owners of several tracks and thereby can ensure the coverage their customers demand. For a new independently owned track to break into that supply chain would be difficult. The revived Oxford stadium would need to successfully negotiate a contract with the media broadcasters and betting companies. There is an argument that demand for broadcast races and supply are already in sync. In the words of the Editor of the Greyhound Star, (August 2019) “The reality is the betting industry funds greyhound racing and it doesn’t need more than a dozen tracks to meet its current and future commitments which rely on internet connections not clicking turnstiles”. There are currently 26 tracks operating in Great Britain – see paragraph 12.

9. Greyhound tracks receive revenues from betting companies and the media companies that transmit broadcasts from the tracks. Many races these days take place on weekday mornings and afternoons, with no crowds, simply to service the betting industry. These “BAGS” (Bookmakers’ Afternoon Greyhound Services) meetings have been an important part of the fixture lists of many tracks. Admission is often not charged.

10. However, recent events are changing the relationship between the betting companies, the media broadcasters and the greyhound tracks. The new limit of £2 on Fixed Odds Betting Terminals in betting shops will lead to the closure of betting shops. William Hill have already announced the closure of 700 betting shops and others are sure to follow. Demand for retail coverage of greyhound racing in the shops will diminish as a result and the trend toward betting on-line will be reinforced.

11. To service that demand, betting companies require all day greyhound racing, with quality fields, at well equipped race tracks with first class media coverage. Location of the track makes no difference to the on-line gambler.

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12. The number of tracks in Britain has fallen significantly over recent years. In 1946 there were 77 GBGB licensed tracks in Great Britain (+200 unlicensed); today there are 21 licensed tracks still operating and 5 independent tracks. The most recent track to close was Towcester (highlighted in the Five Lines report – page 23), newly opened amid a fanfare in 2014 but closed in 2018 when sold to a development company. Attendance levels at tracks also have fallen significantly. Crowds have fallen to an all-time low of two million a year from a peak of 70 million.

13. The Five Lines report referred to the published annual accounts of greyhound track owners and operators, GRA Limited and Sheffield Sports Stadium Limited. Latest accounts from Companies House show a continuing decline in the performance of two of those companies:

Sheffield Sports Stadium turnover: 2016: £6.44m; 2017: £6.18m; 2018: £6.08m GRA Ltd turnover: 2016: £13.56m; 2017: £10.46m; 2018: £7.16m

14. Greyhound racing has lost popularity among those concerned with the welfare of the dogs. Reviving a new track in Oxford is likely to incite considerable hostility from animal rights campaigners. Across the world, tracks have been closed and greyhound racing banned for reasons of animal cruelty. In the USA commercial dog racing is banned in over 40 states with only 5 still operating active tracks. One of these, Florida has just over half of the remaining greyhound tracks left in the US (11 out of a mere 20). It is by far the biggest gambling market for the sport in the US and its revenues have subsidised the sport nationally. Without Florida, the sport may die in the mere 5 states in which it now survives: Alabama, Arkansas, Iowa, Texas and West Virginia. China, the world’s biggest country, reported it has no more regulated greyhound racing following the closure of the final track in Macau recently. In effect, commercial greyhound racing is now confined to six countries: the US, Mexico (1 track), Australia, New Zealand, the UK and Ireland.

15. Welfare concern in the UK has led to a new deal this year worth an estimated £3 million, to be paid for by some of Britain’s biggest bookmakers. The deal follows an acknowledgement by the Greyhound Board of Great Britain (GBGB) which recognised there were ‘avoidable and unnecessary deaths’ of greyhounds and pledged to eradicate them from the sport. The figures, released by the Greyhound Board of Great Britain, show a total of 932 racing greyhounds died or were destroyed last year - and of those a total of 242 died or were put down at the racetrack. The figures also report that 4,963 injuries were sustained by racing greyhounds last year.

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16. However, charities say no amount of welfare commitments could reform or address the suffering of thousands of dogs forced to take part in racing. The Minister for Sport Mims Davies has announced that the funding will contribute towards new tailored training for veterinary staff, the expansion of an injury recovery scheme to ensure more greyhounds can enjoy a full and active life following racing, and the provision of more homes for dogs as they enter retirement, through increased funding for the Greyhound Trust. The fund will not help to launch a new stadium in Oxford.

17. The proposal to include speedway at the revived Oxford stadium will contribute very little toward the viability of the stadium. Even the Five Lines estimates suggest a small contribution from gate receipts and catering toward the stadium’s fixed cost overheads.

18. We have reviewed the estimates made in the Five Lines report for non-race day events. The Oxford stadium is not situated in the heart of Oxford and is in a less prestigious area than many competitive venues. There are many venues in and around Oxford that offer more convenient facilities for public transport, are in attractive historic buildings and/or offer up-to-date hi-tech facilities. Venuefinder.com, advertises 177 venues within 15 miles of the stadium, 97 venues within 5 miles and 14 venues within 2.5 miles. Close by, the Kassam Stadium offers six large conference/function rooms, an exhibition hall and 28 Executive boxes that can be used for small meetings. The largest suite can seat up to 600 delegates theatre-style or be split into four smaller rooms for different events. This level of competition will make it challenging for the Stadium to attract large volumes of conferences and functions.

19. Furthermore, the shape of the restaurant area at the Stadium is curved, and although it may be suitable for 350 diners viewing the races, it would not be ideal for theatre style events or functions of the same number due to the poor sightlines – the market would be smaller dinners, events and conferences. Like speedway, use of the stadium for these activities will produce only a small contribution toward fixed costs.

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THE FIVE LINES CONSULTING REPORT

20. The financial appraisal in the Five Lines report is summarised in Table 4 in the report in an estimated Profit and Loss statement. We have based our review of the viability of the proposed Oxford stadium revival on the estimates contained in Table 4 and the assumptions on which they are based. Table 4 is reproduced below for ease of reference.

Five Lines Consulting Report - Table 4 Year 1 % Total Year 2 % Total Year 3 % Total Year 4 % Total Year 5 % Total Income Income Income Income Income Income Greyhound Gate 468,000 16.5% 468,000 16.5% 468,000 16.5% 468,000 16.5% 468,000 16.5% Greyhound catering 401,700 14.1% 401,700 14.1% 401,700 14.1% 401,700 14.1% 401,700 14.1% Greyhound Gambling 351,000 12.3% 351,000 12.3% 351,000 12.3% 351,000 12.3% 351,000 12.3% Media rights 1,092,000 38.4% 1,092,000 38.4% 1,092,000 38.4% 1,092,000 38.4% 1,092,000 38.4% Speedway gate (% to Venue) 99,000 3.5% 99,000 3.5% 99,000 3.5% 99,000 3.5% 99,000 3.5% Speedway Catering 198,000 7.0% 198,000 7.0% 198,000 7.0% 198,000 7.0% 198,000 7.0% Non-race day catering & hospitality 234,000 8.2% 234,000 8.2% 234,000 8.2% 234,000 8.2% 234,000 8.2% Total Income 2,843,700 100.0% 2,843,700 100.0% 2,843,700 100.0% 2,843,700 100.0% 2,843,700 100.0%

Direct Costs Greyhound Catering Cost of sales 120,510 4.2% 120,510 4.2% 120,510 4.2% 120,510 4.2% 120,510 4.2% Speedway Catering Cost of Sales 59,400 2.1% 59,400 2.1% 59,400 2.1% 59,400 2.1% 59,400 2.1% Non-race day Catering Cost of Sales 70,200 2.5% 70,200 2.5% 70,200 2.5% 70,200 2.5% 70,200 2.5% Greyhound Prize Money 260,000 9.1% 260,000 9.1% 260,000 9.1% 260,000 9.1% 260,000 9.1% Greyhound Event Advertising 26,000 0.9% 26,000 0.9% 26,000 0.9% 26,000 0.9% 26,000 0.9% Greyhound Event Staffing 239,168 8.4% 239,168 8.4% 239,168 8.4% 239,168 8.4% 239,168 8.4% Speedway Staffing 148,500 5.2% 148,500 5.2% 148,500 5.2% 148,500 5.2% 148,500 5.2% Non-race day Catering & Hosp staffing 64,350 2.3% 64,350 2.3% 64,350 2.3% 64,350 2.3% 64,350 2.3% Total Direct costs 988,128 34.7% 988,128 34.7% 988,128 34.7% 988,128 34.7% 988,128 34.7%

Overheads Payroll (permanent) 550,000 19.3% 550,000 19.3% 550,000 19.3% 550,000 19.3% 550,000 19.3% Admin (inc Insurance) 150,000 5.3% 150,000 5.3% 150,000 5.3% 150,000 5.3% 150,000 5.3% Sales & Marketing 99,530 3.5% 99,530 3.5% 99,530 3.5% 99,530 3.5% 99,530 3.5% Repairs & Maint. 125,000 4.4% 125,000 4.4% 125,000 4.4% 125,000 4.4% 125,000 4.4% Utilities 100,000 3.5% 100,000 3.5% 100,000 3.5% 100,000 3.5% 100,000 3.5% Business Rates 150,000 5.3% 150,000 5.3% 150,000 5.3% 150,000 5.3% 150,000 5.3% Re-investment Reserve 56,874 2.0% 85,311 3.0% 113,748 4.0% 142,185 5.0% 142,185 5.0% Total Overheads 1,231,404 43.3% 1,259,841 44.3% 1,288,278 45.3% 1,316,715 46.3% 1,316,715 46.3%

Profit Before Interest & Tax 624,168 21.9% 595,731 20.9% 567,294 19.9% 538,857 18.9% 538,857 18.9%

21. Assumption 1: “The profit and loss statement is an initial illustration of the possible performance over the first five years of trading. This is important because new sports stadia typically take a number of years to reach mature levels of trading performance (i.e., as awareness of the Stadium builds and audiences are developed, staffing and other operating arrangements stabilise, etc.). In light of this, we have assumed that it will take three years for the Stadium to reach its stabilised year of trading”.

Commentary: It is apparent that the general assumption described above has not been followed in the figures. The Table shows exactly the same revenue and cost estimates for each of the first five years of operation with the only change appearing in the Reinvestment Reserve.

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Even if it were accepted that the stadium would reach its ‘stabilised year of trading’ by year 3, for which no evidence is provided in support, the income and direct cost figures would be significantly reduced during the start-up and subsequent build-up of business, whereas the overheads would be substantially unchanged. Any return on investment would be deferred.

22. Assumption 2: Capital Investment – the report suggests that the refurbishment costs to the stadium including tracks and buildings to prepare it for greyhound and speedway racing could be £1million.

Commentary: This estimate appears to be heavily understating the likely costs which have been reported on in detail by Lambert Smith Hampton. The Five Lines report’s preliminary estimate is based upon discussions with ‘an interested third party’. Lambert Smith Hampton’s report following a detailed survey puts the repair and refurbishment cost at an estimated £3.9 million (exclusive of vat and professional fees). The cost of replacing floodlighting required for TV quality broadcasting will add a further £400,000.

The greyhound industry in particular will demand a high-quality facility. To combat concerns around the welfare of dogs, any new stadium would need to be seen to have the best facilities for animal welfare. Furthermore, race broadcasting media demand high quality facilities as a pre-condition of contracts with track owners for live transmission to the betting industry.

And again, when referring to non-race day events, the report itself comments: “The average income assumes that the hospitality space is fitted out to a high quality and marketed effectively so that it is able to compete effectively within the Oxford/Oxfordshire marketplace”.

The capital estimate in the Five Lines report would appear to be significantly understated.

23. Assumption 3: Investment Funding: The Five Lines report argues that the total required investment in the stadium will be covered by a housing development on the western car park site.

Commentary: It is not within our remit to review the development appraisal of the housing scheme, but the estimated residual profit of £870,000 shown in the Five Lines report would be far below the estimated refurbishment costs of the stadium identified by LSH. Substantial additional funds would

Cowley Investments Ltd Oxford Stadium November 2019 7

1 The Old Chapel, Castle Hill, Saffron Walden, CB10 2BS [email protected]; www.johnashworthassociates.com be required, either from the Council or from a third party, to fund the capital refurbishment costs required to relaunch the Oxford stadium.

24. Assumption 4: Attendance Levels at Greyhound meetings: The Five Lines report assumes a programme of three race meetings per week all year round with an average attendance of 750 per meeting.

Commentary: The reality is that in 2019, no midweek meetings have been held at any greyhound track in England except for those being sold into betting shops. Five tracks do not even hold meetings on a Saturday night.

Attendances across all the greyhound tracks in GB have fallen to an estimated 2 million. That is the equivalent of around 1500 visitors per week to each track. The revived Oxford stadium would need to significantly outperform the market to reach the estimated visitor numbers of 2,250 per week contained in the Five Lines report.

The industry trends are illustrated in the company accounts of GRA Limited. Directors of GRA Limited in the company’s 2018 annual report stated that the company staged 449 events in the year attended by 115,000 customers (the numbers were 618 and 223,000 in 2017) at an average attendance of 256 (360 in 2017) – the events included stockcar and speedway racing as well as evening and daytime greyhound racing. Two of GRA’s stadiums, Hall Green and Wimbledon, were closed in 2017. The Directors state: “Declining attendance levels continue and a review of evening meeting financial performance has been carried out. It is expected that both [their remaining] tracks will limit evening racing to Saturday only”.

At the Oxford Stadium, at 1500 visitors per week to greyhound meetings, based on two weekend meetings and some sparsely attended midweek daytime meetings, greyhound gate receipts would total £312,000 per year at an average entry fee of £4 compared with £468,000 as shown in the Five Lines report. Catering receipts at greyhound meetings would total £267,800 compared with £401,700 in the Five Lines report based on an equivalent average spend per head. The combined effect would be a reduction in revenues of £289,900 per year.

Cowley Investments Ltd Oxford Stadium November 2019 8

1 The Old Chapel, Castle Hill, Saffron Walden, CB10 2BS [email protected]; www.johnashworthassociates.com

25. Assumption 5: Greyhound Gambling Income and Media Rights: These two sources of revenue represent 50% of estimated total income in the Profit and Loss estimates for the stadium. They are crucial to the assumed viability of the stadium. Yet our investigations suggest they are most unlikely to be achieved.

Commentary: Tote income is estimated in the Five Lines report at an average of £15,000 per meeting of which 15% would be retained by the stadium. The totalisator at greyhound racetracks is normally operated by the occupier of the track (in contrast to the tote at horse racecourses) and the money retained from amounts staked has traditionally formed an extremely important (if not the most important) element of gross receipts upon which many stadia are heavily dependent. The assumption is that 750 visitors would bet £20 per head on average at each meeting. If average attendance levels are well below 750 (see above), these estimates are overstated. If attendance levels averaged 1500 per week, annual receipts from the Tote would be £156,000 compared with the reports estimate of £351,000.

Media revenue is estimated by Five Lines at £7,000 per race meeting, totalling £1,092,000 over the course of a year. Although media revenue will be crucial to the viability of the revived stadium, there is no valid justification for the level of revenue estimated. To service on-line demand, betting companies need to broadcast races, no matter where they are held. And the demand will be for morning and afternoon race meetings – the proposal for three evening meetings per week, as discussed above, is unrealistic and in any case, does not respond to the betting companies’ core demand. Indeed, there is a view in the industry that the betting and media companies’ policies in recent years to purchase and own their own stadia will cap their demand for coverage from independent operators. A new stadium cannot expect to acquire a lucrative deal from the betting companies until it has established itself and can supply racing that meets the betting industry’s needs. The most recently opened new stadium, at Towcester, failed to do that and closed within 4 years. Paradoxically, supplying racing during daytime periods may attract the betting and media companies, but with rock bottom visitor numbers at those meetings, nothing of the historical popularity of the greyhound industry will be commemorated.

26. Assumption 6: Risk factors and sensitivity analysis: the sensitivity analysis in Table 5 carries the footnote that ‘only the variable mentioned’ is revised in each case.

Cowley Investments Ltd Oxford Stadium November 2019 9

1 The Old Chapel, Castle Hill, Saffron Walden, CB10 2BS [email protected]; www.johnashworthassociates.com

Commentary – this approach inevitably understates the multiplying effect; for example, a decrease in attendance will have negative implications for all on course spending (the Tote, food & beverage) as well as on gate receipts.

27. Assumption 7: Speedway: in our earlier report of December 2018, we concluded that average gate attendances for speedway at the Oxford Stadium are more likely to fall within the 500-1000 range than anything higher. The Five Lines report assumes 22 speedway meetings per year with an average attendance of 1500 from which the stadium will benefit from a percentage of gate receipts plus catering income.

Commentary - it is apparent from the figures in Table 4 in the Five Lines report that total receipts from speedway are estimated at £297,000 pa and direct costs at £207,900 showing a contribution to overheads of £89,100 or just 7%. Even at that level, speedway is doing little to underpin the viability of the stadium; and represents an activity that because of noise levels is unlikely to be well received by adjoining residential neighbours, assuming the proposed residential development on the western end of the site goes ahead.

28. Assumption 8: Non-race day events and catering: total receipts are estimated in the Five Lines report at £234,000 pa and direct costs at £134,550 showing a contribution to overheads of £99,450 (8%). The estimates assume 7,800 customers per year, the equivalent of 150 per week, spending on average £30 excluding vat. Day delegate rates at the nearby Kassam Stadium are advertised from £29 to £33 excluding vat at a venue that is better configured and equipped – see paragraph 18. In that market, to achieve an average spend of £30 would be challenging and, even if possible, is likely to require a build-up of 2 – 3 years of effective marketing to achieve both the level of customers and the average spend.

Cowley Investments Ltd Oxford Stadium November 2019 10

1 The Old Chapel, Castle Hill, Saffron Walden, CB10 2BS [email protected]; www.johnashworthassociates.com

CONCLUSIONS

29. Modern day greyhound racing is a service to the online betting industry – to suggest that its revival at the Oxford stadium in its modern guise will preserve the memory of the historical popularity of the sport as a visitor experience is misguided. The site will lie empty of visitors for most of the time.

30. The estimated capital costs of repair and refurbishment are more than four times those estimated in the Five Lines Consulting report. The proposal that they are funded from adjacent residential development is unrealistic.

31. The profit and loss statement included in the Five Lines report fails to reflect the build-up of revenues which would be an inevitable characteristic of the launch of a new stadium; and overstates the likely quantum of revenues over the first five years.

32. Uncertainty about the level of estimated revenues from media and betting companies, shown as over 50% of total revenues in the Five Lines report, challenges the conclusion that the revived stadium would operate at a profit; in any event, the level of estimated profit fails to demonstrate the viability of an investment in the revival of the Oxford Stadium, given the cost of reinstatement.

33. Universal concern about the welfare of greyhounds involved in racing has led to the banning of the sport in countries across the world. The revival of greyhound racing at the Oxford Stadium would most likely be met with strong protests from animal rights campaigners and mixed popular opinion – a scenario that does not represent a positive response to the Inspectors’ question Can the Council provide sound and up-to-date evidence to demonstrate that the revival of greyhound racing and/or speedway is a viable and attractive proposition for operators and site owners?

Cowley Investments Ltd Oxford Stadium November 2019 11

1 The Old Chapel, Castle Hill, Saffron Walden, CB10 2BS [email protected]; www.johnashworthassociates.com

APPENDIX

JOHN ASHWORTH ASSOCIATES

John Ashworth Associates is a UK consulting and business advisory firm providing services to the leisure, sports and tourism industries across the commercial, public and voluntary sectors.

Our main areas of business comprise: Market Appraisal, Concept Development and Viability Studies Investment Appraisal and Business Planning Planning Applications and Supporting Expert Reports Expert Witness at Tribunals, Inquiries and Hearings Master Planning and Strategy Studies Operational Support and Product Repositioning Business Purchase Due Diligence Further information is available from our web site at www.johnashworthassociates.com

This report has been prepared by John Ashworth Associates based on third party reports, our own experience and information available to us through the Internet. Where we have relied on third party reports and the Internet, although we have not independently verified the information provided, we have used due care in its use and we have cross-checked it wherever possible. Nevertheless, we do not accept responsibility for any inaccuracies that do occur.

Cowley Investments Ltd Oxford Stadium November 2019 12

11 November 2019 L 111119 RAS Letter to Cabinet on Behalf of Cowley Investments Limited

Councillor Susan Brown Members Room Town Hall Roger Smith St Aldate's E: [email protected] Oxford DL: +44 (0) 1865 269 057 OX1 1BX Wytham Court By email to: [email protected] 11 West Way Oxford OX2 0QL T: +44 (0) 1865 269 000

F: +44 (0) 1865 269 001 savills.com

Dear Councillor Brown

RE: Cabinet Meeting on Wednesday 13th November 2019, Agenda Item 9, Oxford Stadium

I am writing to you in my capacity as the planning consultant representing Cowley Investments which owns the site of the Oxford Stadium.

I have read the Cabinet report (the report) regarding the Oxford Stadium which will be considered by Cabinet on Wednesday 13th November 2019. You will be aware that this is a large brownfield site in a sustainable location that offers the potential to provide a significant number of new market and affordable homes.

The Council has however made the Stadium the subject of Policy SP52 in the Oxford City Local Plan 2036, identifying that it will reopen for greyhound and speedway racing, or failing that as a venue for community or leisure uses. Allowance is made in the policy for an amount of enabling development in the form of housing on the car park or other areas that will not affect the operation or the heritage interest of the stadium. The enabling development is intended to fund necessary improvements to the Stadium to facilitate an on-going financially sustainable future with income principally from greyhound racing and speedway racing. In preparing the Policy the Council has received advice concerning the financial viability of reinstating the stadium from Five Lines Consulting.

Cowley Investments would like to bring to your attention three concerns that they have in relation to the information provided in the report as set out below.

Viability of reinstatement of the Oxford Stadium

In the report the Cabinet have not been advised that Appendix A of the Council’s March 2019 Housing and Economic Land Availability Assessment (HELAA) concludes that reinstatement of the Stadium as proposed by Policy SP52 is “non-viable” (although consultants advising the Council – presumably Five Lines – took a different view). Relevant extracts are enclosed.

Deliverability of enabling development

Paragraph 6 of the report identifies that the scale of enabling development at the Stadium would be in the order of 100 homes. This is not consistent with the Five Lines advice that is based on an illustrative scheme of 52 houses and flats on the western car park only. It is also inconsistent with Appendix B of the HELAA, which indicates that the whole 3.37 hectare site could accommodate 100 homes - but only if the greyhound track were to be redeveloped. We are not aware of anything published by the Council to date that illustrates how 100 homes could be accommodated on the western car park area, or any other part of the site, whilst still allowing the Stadium and its associated car parking to operate for greyhound racing and speedway racing. There is concern therefore that the enabling development proposed is undeliverable.

Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East..

Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

Support for gambling

The report identifies that as a last resort the Council will make use of compulsory purchase powers to acquire the Stadium. By doing so the Council would be providing support for a business which will rely on gambling income associated with greyhound racing. This appears to be at odds with the principles of the Council’s Ethical Investment Policy, which states that the Council will not invest in socially harmful activities, identifying gambling as an example. The principles of the Ethical Investments Policy should apply to all of the Council’s activities and not only the investments it makes. This is particularly relevant in the case of the Stadium, as modern day greyhound racing is mainly operated as a service to the betting industry, with the majority of events conducted in the daytime, on weekdays, and televised into betting shops or online without any spectators being present at the Stadiums where the events are being run.

Conclusion

The Stadium site provides a major opportunity to provide new family market and affordable housing on a brownfield site in a sustainable location. In the absence of any evidence to support the assertions made in the report about the deliverability of enabling development, and in light of the need for the Council to conduct itself in an ethical manner, we urge the Cabinet not to endorse the officers recommendations.

Yours sincerely

Roger Smith Head of Department