How to object to the OUFC Planning Application:  Key Points

These Key Points are a summary of the material planning considerations which the council should consider.  You don’t have to read them all!  Look at the main headings below.  Choose points that you think are important and build them into your own response. Please ensure you read our general guidance in conjuction with these points.

 

Traffic congestion  and road closures – these should be major concerns for the councils

 

·         OUFC used the wrong traffic modelling tool. The correct VISSIM traffic modelling is being carried out at the moment and is not yet available.  Suggest you say this means that you can’t comment on the traffic modelling at the moment but will do so when the data is available.

 

·         Road closures (referred to as ‘diversions’) are planned despite Oxfordshire County Council’s statement that the Oxford Road cannot be closed.  Surely therefore the County Council must object to the planning application?

 

·         Road closures for  “at least 30 minutes” before and after matches are planned on matchdays which include Saturdays.  30 mins is a minimum.  Much longer delays are probable in practice. 

 

·         Extract “Key bus services and coaches will be marshalled through Oxford Road during periods of lighter pedestrian flows”.  30 minutes is a short period of time to move 16,000 people so lighter flows will be unlikely in this time.  This means bus delays on matchdays which include Saturdays. 

 

·         The diversion route (via Loop Farm Roundabout, Peartree Roundabout, Wolvercote Roundabout and Cutteslowe Roundabout) is already heavily congested and there will be even more traffic when the diversion is in place and people are trying to access the stadium.

 

·         The amount of Park & Ride parking in the area is going to encourage fans to travel by car thus adding to congestion.

 

·         The proposal states that ‘many of our fans live within 20 minutes walk, cycle, or on public transport of the proposed location’ – this is incorrect: the main fan base is in East Oxford and public transport, cycling or walking would be a challenge.

 

·         New pedestrian crossings on the Oxford Road and Frieze Way will cause even more congestion on the Kidlington Roundabout and Peartree Roundabout, particularly if events/matches at the proposed site coincide with heavily-attended events at Blenheim Palace.

 

·         A footbridge is needed to avoid road closures and should form an integral part of this planning application, not a separate one.

 

·         Coaches/shuttle buses from the Park & Rides will unload at Oxford Parkway leading to further congestion. 

 

·         It has been suggested that coaches may unload on Frieze Way which would take the diversion route down to one lane.

 

·         The bus lane on the east side of the Oxford Road appears to be removed in the plans.  This will cause significant daily delays for buses travelling to Oxford in the rush hour and conflicts with  local transport policy.

 

·         There is no evidence that many supporters will travel by train, most of the League One fans would find this very challenging and expensive.

 

·         The Fan Travel section of the Sustainability Statement is based on surveys of football supporters, many of whom have a vested interest in the stadium moving.  This is therefore not a reliable source of data

 

·         83.1% of supporters currently travel by private car/van.  The club “has an aim that 90% of fans will travel to the Stadium by sustainable modes” but no realistic means of achieving this.  It is therefore probable that most fans, attracted by parking at Park & Rides, are likely to travel by car.

 

·         What about the safety of non-football cyclists and pedestrians who want to use the pedestrian paths and cycleways on matchdays and find themselves caught up in large numbers of fans?

 

·         Concerts are “not proposed” but they will be if the opportunity arises!  What about traffic management for these and other large events that are likely to take place? 

 

·         A lot of buses/shuttle services are planned, including from the various P&R sites where fans plan to park.  There doesn’t seem to be any modelling of the impact of these, to include the unload times.  Will they simply get caught up in the diversion traffic and where will they wait during the match?

 

·         The additional Toucan crossings on Frieze Way and the Oxford Road will cause further local congestion on matchdays, including on the diversion route and the Kidlington Roundabout.

 

·         Thames Valley Police concerns that fans won’t use designated crossing routes have not been addressed. 

 

·         Traffic holdups have the potential to affect the strategic road network (eg A34 & A40)

 

 

Parking provision

 

·         184 parking spaces and 2 coach bays in total on site is inadequate given current established supporter travel patterns.

 

·         Inadequate onsite parking will lead to the loss of community parking facilities at the Park & Ride with knock-on impacts to businesses in Oxford due to loss of trade as commuters switch to other more accessible shopping destinations.

 

·         The Design and Review Panel recommends that onsite parking should be reduced as part of a strategy to address spatial constraints.   FoSB agrees even though the onsite parking is already inadequate!

 

·         Cycle parking should be provided at 1 space per 50 seats. That is 320 spaces rather than the 150 proposed.  OUFC is planning to use the Oxford Parkway cycle racks which is not acceptable and against local transport policy.

 

·         There is little evidence to suggest that incentives for fans not to park at Oxford Parkway will be effective. 

 

·         The club has little influence over the travel patterns of away supporters.   

 

·         Match Day Controlled Parking Zones (CPZs) are proposed. This indicates that the applicant knows that a significant number of fans will continue to travel by car and will cause significant issues for local residential areas.

 

Extract:  “Match Day Controlled Parking Zones (CPZs) will be implemented up to 2km from the Stadium in Kidlington, North Oxford and Yarnton. These will operate during matches (Saturday and evenings) and will discourage supporters travelling to stadium by car and parking on nearby residential streets on match days. These Match Day CPZs will dovetail with the parking management strategy emerging for the PR Sites around Kidlington and Oxford Parkway.”  (Note:  The ‘PR’ sites are the developments already planned for the Kidlington Gap)

 

o   How can a CPZ only operate during matches?  This is not how CPZs work.

 

o   Detailed proposals on CPZs should be consulted on locally, not installed unilaterally.

 

o   This has limited effect as a deterrent because the cost of a  parking fine shared between 4 or 5 people is cheap parking. 

 

o   Is it enough to "discourage” supporters from parking on residential streets?  Surely it should be prevented?

 

o   What about CPZs for other large events that are inevitable?

 

o   This does not dovetail with the strategy around the PR sites which, at least on the largest (PR6a), is to prevent commuter parking.

 

·         If the Park & Rides are full of fans’ cars, where will users who wish to use the P&Rs to access Oxford and the hospitals park?

 

·         How will reduced capacity at the P&Rs for current users due to fans taking over the facility impact the already struggling Oxford City traders?

 

·         If the P&Rs (especially Oxford Parkway) are already full when fans start to arrive, what plans are in place to manage this?

 

·         Have the calculations of the P&Rs capacities taken into account the planned traffic filters/bus gates and workplace parking levy?

 

·         How would parking in other areas such as Stratfield Brake, Exeter Hall and Cutteslowe Park’s two car parks be managed to ensure continued use of these areas is possible for other users?

 

 

Government policy and guidance:  Green Belt

 

·         The NPPF (National Planning Policy Framework) states that inappropriate development on the Green Belt is not allowed unless there are ‘very special circumstances’ (VSC)

 

·         OUFC acknowledges that the stadium is inappropriate development and that it would cause harm to the Green Belt but tries to justify it with ‘very special circumstances’ as follows:

 

o   The club has to find a new home by 2026.  FoSB says the club made itself homeless and hasn’t tried to negotiate to stay at the Kassam Stadium (because it doesn’t want to) so can’t claim this as a VSC. Please tell Cherwell District Council that it needs to challenge OUFC's claims. This must include contact with Firoka, the stadium company, to confirm their position.

 

o   There is no other available suitable site. FoSB says the Alternative Sites Report was pre-determined and therefore unreliable and invalid because it was prepared after the event (ie after the lease had been agreed by the County Council cabinet) to provide “justification for the application site, which is the Club’s identified location for the stadium and ancillary facilities”.  (Alternative Sites Assessment para 1.2).

Also, the Alternative Sites Report says that one of the reasons the Kassam Site was not considered further was because "Landowner confirmed not willing to allow continued use or sell." The appendices show letters relating to other sites where there is a significant reason not to proceed with further consideration, but no evidence is shown for the Kassam Site. Furthermore, this statement conflicts with information in the public domain where the owner has stated it is possible for OUFC to stay at the Kassam Stadium.

 

o   There will be benefits to the Club associated with the financial sustainability of owning their own stadium.  FoSB says there is no guarantee that the club will own its own stadium, in fact it is likely that it will not!  Nor is it likely to own the conference facilities, or hotel, or the commercial retail sites that it thinks will generate revenue.  Even if the current owners say OUFC will own these the club could be sold and the situation could change overnight.

 

o   There will be social and community benefits.  FoSB says these are not guaranteed because the funding is not guaranteed, and anyway they could be delivered from the current stadium.

 

o   Economic benefits:  FoSB says much of this could be delivered at the Kassam Stadium where it would arguably be of more benefit.  And again the figures seem overly optimistic.  The economic disadvantages to Oxford’s city centre are overlooked.  Full Park & Rides because the fans got there first and additional traffic will not help struggling retail outlets in the City. 

 

o   Environmental benefits:  FoSB says the most environmentally friendly solution is to stay at the Kassam Stadium, particularly with the Cowley Branch Line in the pipeline.  The Club’s aim for the Proposed Development is to achieve at least a BREEAM rating of ‘Very Good’.  Aims are not guarantees! And a ‘Very Good’ is a low bar.  The sustainability of demolishing a perfectly functioning 23-year-old concrete stadium and replacing it with a new one, outside of the City of Oxford is directly at odds with all Oxfordshire Councils Climate Crisis promises.  

 

o   Sustainable travel:  FoSB says the Club “has an aim that 90% of fans will travel to the Stadium by sustainable modes” however there is no effective strategy in place to achieve this.  Many (or based on current travel patterns, most) fans will be attracted to the parking at the Park & Ride sites.  The potential for OUFC to impact how away fans travel is limited. 

 

o   Biodiversity enhancement:  FoSB says that the development will not deliver a 10% biodiversity net gain.  See our detailed comments on this on our website in our FoSB ecology comment document.

 

o   Improved access to the Green Belt:  FoSB says these claims are disingenuous because the amount of open Green Belt and green space will be minimal.  The garden area is only about the size of the Kidlington Roundabout and the heavy footfall will mean it won’t stay green for long.  Also, on match days the plaza and garden will be a fan-zone, so we presume only really accessible to the general public on other days!  No public rights of way are being created over the site. 

 

 

Nature conservation

 

·         There is reason to believe that the bat and reptile surveys which took place from August 2022 to October 2022 were not conducted properly. The resulting data is therefore unreliable and must be repeated. 

 

·         The number of breeding bird surveys is insufficient and the timing, only in June, missed the important March – May period.  Further survey work is therefore required for an accurate assessment of breeding birds.

 

·         Plans for a proposed wildlife-rich green area at the northern tip of the site are totally unrealistic.  This area and the northern plaza will be a fan-zone on matchdays!  With 16,000 or more people on site, and the location of the green area next to public areas designed for socialising etc, the probability of this area remaining green and enabling wildlife to thrive is zero.  (This area is a key part of the flawed strategy for a 10% Biodiversity Net Gain).

 

·         BBOWT previously commented that it would be necessary to have segregated areas with no public access.  Cherwell DC’s Ecology Officer also stated:  “The very high level of public use of the site which will occur at certain times will necessitate some areas to be retained and managed solely for biodiversity to ensure habitats can function”.  The planning application seems to entirely ignore these fundamental recommendations which were made at an early stage by important stakeholders.

 

·         The ecology report ruled out the presence of Great Crested Newts too early.  Further  survey work must be undertaken for this protected species which may be present on the site.

 

·         The development will not achieve the 10% Biodiversity Net Gain required by the emerging policy, Core Policy 14: Natural Capital and Ecosystem Services (CP14) which is included in the draft Cherwell Local Plan Review 2040.  

 

·         The ecology report understates both the level and abundance of biodiversity that exists on the site and on the adjacent woodland to the south.  (NOTE: this woodland is adjacent to the site, not part of it but will be impacted).

 

·         Importantly the proposed mitigation strategy is unrealistic because it fails to consider the timings of losses and gains, or the cumulative effect with other developments, there is no plan for ongoing management for diversity, any plan would be dependent on the financial security of OUFC which is not a certainty.

 

·         There is evidence the woodland to the south of the site is in fact Ancient Woodland and it requires more protection than is currently planned, including an appropriate buffer zone. 

 

·         This strip of woodland is included in the proposed Nature Recovery Network for Oxfordshire by Thames Valley Environmental Record Centre (TVERC) as part of a ‘Core Zone’  ie of the ‘highest nature value’, existing wildlife areas.

 

·         The woodland is notable for the amount of standing dying trees, deadwood, dead stumps and rotting coppice stools which create an extensive and valuable habitat for fungi and saproxylic (deadwood-breeding) insects. 

 

·         The woodland’s valuable habitat is not sufficiently recognised by the Aboricultural Report.  It is important that no deadwood is removed.

 

·         Bats, including rare species such as Barbastelle, use the site, particularly the southern area by the woodland.  This woodland contains many bat roosting opportunities. 

 

·         An independent ecologist’s report by Dr Judith Webb records 161 invertebrate species including 42 beetles, 17 butterflies, 7moths,1 lacewing, 4 dragonflies & damselflies, 20 true bugs, 17 bees & ants & wasps, 1 sawfly, 6 grasshoppers & crickets, 30 true flies, 2 molluscs, 14 spiders & harvestmen. Dr Webb also states this is just a small range and nothing like the full species diversity of invertebrates that will be present. 

 

·         Dr Webb also noted that common plants can support rare insects e.g. the Common Fleabane on site yielded several individuals of the small and rare picture wing fly (Tephritid) Myopites inulaedyssentericae.  In this context Ecology Solutions’ statement that an assemblage of common invertebrate species would be present within the site is just one example of the biodiversity of the site being understated. 

 

·         The non-intensive rotational willow coppice management of the site centre has helped to maximise biodiversity on the site, especially of flowers and invertebrates.  Willow can support a big total of invertebrate species; one quote is up to 450 dependent species, which will include: bugs, bees, beetles, flies and moths.

 

·         Both the range and abundance of invertebrates noted by Dr Webb are relevant for other species further up the food web, including birds and bats which, given the current absence of street lighting along the A4620 Frieze Way, are also likely to be commuting from the bigger Stratfield Brake western woodland area to forage on the site.  The removal of this food source would directly impact bats and birds who forage on the site but next and roost elsewhere. 

 

·         In her report on the woodland Dr Webb also explains the important inter-relationship between the woodland and the site which would be completely lost as a result of the development. As Dr Webb observed, insects which breed in the woodland will be using flowers on the site as a food source.

 

·         Branches from the woodland may overhang the site over the southern attenuation pond area.  This would not be ideal because the leaves and branches will require constant removal.  Otherwise they are likely to block the hydrobrake structures in the outflow pipes.  There is a danger that someone will decided to cut the trees back for this reason and this would be very damaging to the woodland. 

 

·         The proximity of the development including the car park, the southern area and the stadium itself to the woodland is a serious concern. Destruction of woodland can occur by development near or immediately adjacent as a result of hydrology change, light pollution, noise pollution, too much public access and trampling of flora, litter, flower-picking/digging, fires destroying trees or deadwood.  There is an obvious potential for all of these dangers to the woodland and the protection measures as currently planned are grossly inadequate.   The planned deterrent to entering the woodland will be a hedgerow (as yet to be planted), scrub planting and attenuation features.  This will be ineffective with 16,000 people onsite.

 

·         The ecologist’s proposal that the notable species of flora such as Narrow-leaved Bird’s-foot Trefoil and Corn Mint will be retained “wherever possible on Site and safeguarded during the construction phase”. Inclusion of the words “wherever possible” make this plan meaningless because the amount of development planned for this small space makes the probability of this happening zero.

 

·         Where plantation of notable species is not feasible, such as with the orchids, the ecologist recommends a transplantation method where the plants will be moved to where these species can be retained on site post-development. We are told that in this circumstance, for example, Narrow-leaved Bird’s-foot Trefoil will therefore become part of a more appropriate meadow management scheme potentially resulting in an enhancement over the existing situation.  This is pie-in-the-sky!

 

·         For more information please see Dr Judy Webb’s full ecology reports on the Triangle and the adjacent woodland.  Bullet point summaries are also available.

 

 

Impact on trees

 

·         The proposal will result in the total loss of 17 trees; 5 groups of trees and the partial loss of 2 groups of trees.

 

·         The Section 41 NERC protected and biodiverse woodland to the south of the development will be adversely affected by pollution, light, noise etc

 

·         Measures to ‘deter’ access are totally inadequate.  Large numbers of people onsite will inevitably lead to overspill into the woodland.  The planned deterrent to entering the woodland will be a hedgerow (as yet to be planted), scrub planting and attenuation features.  This will be ineffective with 16,000 people onsite.

 

·         Two oaks with Tree Protection Orders (TPOs) are planned for removal to allow access.  These have bat roosting potential and are protected by TPOs for a reason and should therefore remain.

 

·         While the aboricultural report may consider that these TPO’d oaks are not in their prime, that is insufficient justification for their removal and downgrading on this basis should not be entertained.  As they age, the trees will provide even more value from a biodiversity perspective.  Rot holes and deadwood are normal in trees and home to many animal and fungal species.  It is normal for oaks to go stag headed (ie with dead branches) in the crown and reduce their canopy. They can live on for 100s of years.  Reducing the canopy is a strategy to reduce transpirational losses, it does not mean they are in poor condition and about to die.

 

 

Drainage and flood risk

 

·         The site is susceptible to significant surface water flooding

 

·         In recent wet weather (end of 2023/early 2024) the site has acted as a holding area for vast quantities of water, and has absorbed run-off from the Oxford Road during heavy rain.

 

·         The stadium development will mean that run-off from the Oxford Road has to go elsewhere and this could result in the road and other local flooding.

 

·         What will the cumulative effect of the developments in the area have on flooding?

 

·         This will become more important as climate change progresses

 

Design, appearance and materials

 

·         The Design and Review Panel report says: “…there is a general feeling that everything is ever so slightly squeezed and that there is no spare land.”  (Note: Para 138 of the National Planning Policy Framework says “local planning authorities should have regard to the outcome from these processes, including any recommendations made by design review panels”.

 

·         FoSB agrees, this is clearly overdevelopment in an attempt to fit too much onto a constrained Green Belt site.

 

·         At nearly 25m high the stadium will dominate the landscape and will be obtrusive in what will eventually be a largely residential area on the outskirts of Kidlington.

 

 

Landscape impact

 

·         The landscape and Visual Impact Assessment (LVIIVA), para 7.222 states:  “The Site is generally viewed in the context of the existing vegetation and nearby built form. Beyond this, due to the combination of topography and vegetation, the Site is not readily discernible or apparent”. 

 

·         Para 7.233 “At Year 1 of operation significant adverse effects are considered to occur to two contextual landscape receptors, five Site landscape receptors and two visual receptors in the immediate local environs to the Site. These effects are considered to be permanent and medium - long term”.   (Note: contextual landscape receptors are the effects on landscape receptors beyond the Site boundary, for example, direct and indirect effects on landscape character.  Site landscape receptors are the effects on landscape receptors within the Site boundary only).

 

·         Para 7.235 “At Year 15 of operation the landscape proposals are considered to have matured and the assessed effects are therefore considered to be the residual effects of the Proposed Development. Significant adverse residual effects are considered to remain to one contextual landscape receptor, five Site landscape receptors including Minor - Moderate Beneficial effects to landscape features due to the scale of the landscape proposals, and two visual receptors. These effects are considered to be permanent and long term.”

 

·         7.237 “The scale and massing of the Proposed Development means that it would be visible above the retained boundary vegetation from some roads and PRoWs within the local area”.

 

 FoSB says:  The stadium, at nearly 25m high, and covering most of the site, would dominate the landscape.  It would transform an area that is currently not really apparent (as stated in the LVIVA above) and be an overbearing feature in what will be a largely residential area.  It would also urbanise the last remaining Green Belt gap between Kidlington and Oxford and  impact the setting of the Stratfield Brake Nature Reserve.  It is clear from the above LVIVA extracts that there will be permanent and significant adverse effects on the surrounding landscape.

 

 

 

Environmental pollution e.g. noise

 

·         Increased traffic will lead to increased air pollution in the area

 

·         The attenuation ponds will be subject to pollution from eg the car parks/pedestrian routes (eg from salt used in cold weather and fuel spills)

 

·         More light pollution including on Frieze Way which is currently unlit.  This could adversely affect the wildlife on the Stratfield Brake Nature Reserve eg bats.

 

The Cherwell Local Plan

 

·         The stadium is not included in the Local Plan.  The site was left as Green Belt.  The Planning Inspector noted that, on this basis, “….the overall sense of separation between Kidlington and Oxford in particular, would not be harmfully reduced.”  Development of the site will remove the last remaining separation of Kidlington from Oxford. 

 

 

 

OTHER POINTS

 

Entry, Exit and Evacuation and Major Incidents/Disaster

 

·         The site is:

 

o   bounded by busy roads

 

o   too small for the level of proposed development (reference Design & Review Panel statement:  “…there is a general feeling that everything is ever so slightly squeezed and that there is no spare land”)

 

o   constrained by features such as the car park, woodland and attenuation ponds

 

·         There are few access points into the site and there is a difference in level from the highway to the stadium.  In the event of an emergency it is impossible to see how the stadium could be safely evacuated within 8 minutes.  Similarly it is impossible to see where people could muster safely.   

 

·         The planning application lists laws and regulations but fails to address key safety issues. 

 

·         In general there is a lack of safety both for spectators, for users of the adjacent roads, and members of the public who are not involved in the football. 

 

·         There is also insufficient room to allow for segregation of home and away fans.

 

·         The Design & Review Panel (which the local authority should have regard to) commented:

 

“There is a concern that the proposed main entrance area point to the stadium may not be able to safely accommodate the sheer volume of fans. It is felt there may not be enough arrival space to accommodate the supporters before they disperse to their seats. A lack of space in this area could also give rise to problems of supporter segregation. The practical problems of access are also accentuated by the difference in levels from the highway.”

 

This is clearly a safety issue. 

 

·         The safety issues around access to and egress from the proposed stadium site are not addressed in the documents supporting the application other than by a request for the planning consent to be conditioned.

 

 

Oxford Parkway Station Safety

 

This station is small and unsuitable for crowds of fans, mixing both home and away, and arriving en masse.  The platforms are narrow as is the footbridge across the track.  Fans and other users will be at risk.   

 

 

Energy Efficiency

 

Extract:  “The stadium will be constructed to achieve the highest economically viable energy efficiency……”  

 

This pledge is made meaningless by the phrase: achieve the highest economically viable energy efficiency!

 

 

Economic benefits

 

• The area around the proposed site does not need additional employment opportunities of the type likely to be offered by this development. Local businesses have closed in Kidlington due to lack of staffing.
• Chapter 15 of the Environmental Statement shows that most of the socio-economic effects are of neglible or minor significance to the area, the remainder are moderate, and none are high. And the effect of regular road closures and overloaded Park & Rides is likely to outweigh any possible benefits in any event!