Headington Hospitals. Kill and Cure?

Headington’s Hospitals – Killing and Curing Us?

Introduction

The presence of the vast Trust (OUH) car parks is now no longer morally, ethically, or socially acceptable faced with two key pieces of evidence we now have before us:

  • The climate emergency
  • The estimated 40,000 people who die each year from air pollution

Each year in the UK, around 40,000 deaths are attributable to exposure to outdoor air pollution, with more linked also to exposure to indoor pollutants.[1]

particularly when one of the stated reasons for the high level of parking provision by the Trust is staff attraction and retention.

Oxford City Council (OCC) has always incorporated a “must reduce parking, or minimise parking” clause in all its Site Planning Policies but this has been struck down by the Inspectors of the new draft Oxford Local Plan currently under inspection, stripping the Council of all effective power to control private car parking, most importantly at the Headington Hospitals, namely the John Radcliffe, Churchill and Nuffield Orthopaedic Centre (NOC) run by Oxford University Health NHS Foundation Trust (“The Trust”).

The Trust seeks to be able to INCREASE parking on site.

However, the harm the current parking levels at the Headington Hospitals, namely the John Radcliffe, The Churchill and the Nuffield cause to our planet, our children’s and own health, and our fair city is so severe that acquiescence and tolerance are no longer sustainable.

This can only exacerbate Oxford’s truly appalling  carbon footprint, increasing our contribution to climate change, and continue to poison us and our children with noxious fumes which KILL.  

We are faced with a climate and health emergency and a social and economic disaster – the current position of the Trust is irresponsible, reckless and dangerous and killing our citizens and for the reasons below, UNACCEPTABLE, THIS MUST STOP NOW.

It is the height of absurdity to declare a climate emergency in Oxford and allocate £19 million to combatting it, while allowing the Headington Hospitals to continue with acres of destination parking.

Oxford has become a polluted, dirty, unpleasant city with miles of tailbacks into and out of the city every single day at any time of the day.

Tired people spending hours more away adds to family stresses and is making Oxford, in particularly Headington, an unpleasant place to live and adding economic costs that are ultimately borne by all of us.

We are all grateful to the NHS, and criticising it or any part of it we do with the reluctance and reticence normally reserved for a beloved auntie that shouts too loudly as she is so profoundly deaf.

The issue is complex, and culpability lies in many quarters, and is to a degree irrelevant – what matters is to tackle and solve this with a degree of urgency and commitment that is appears clearly absent from all parties involved.

The last hearing on the issue was held on Dec 11th 2019, the Trust was absolutely unrepentant and pushed its case again for an INCREASE of parking provision with new development,  nothing it seems will trump “operational requirements” and the necessity to “attract and retain staff”  not the climate emergency, nor the unnecessary deaths and health impacts, not the sheer misery it is inflicting on this city.

Appeal

We can no longer idly stand by and allow this entirely avoidable catastrophe to unfold in our fair city, our contribution to climate change, the damage done to the environment, our children’s health, is NOT acceptable in 2019 – the issue is URGENT.

We would not stand idly by and watch approximately 100 of our fellow citizens being taken out and shot annually, or worse allowed to die slowly each year with equanimity – but that is the consequences of our failure to act to combat air pollution in the city as a whole.

Oxford City Council has failed, Oxfordshire County Council as failed, the Trust has failed it is now time for us, the citizens, to make it clear this can no longer be tolerated and a solution for all MUST be found, and found urgently.

Summary Points

  • There is well founded scientific evidence that we are risking our very survival due to climate change by CO2 and other emissions
  • 40,000 people a year die from air pollution in the UK which is approximately 100 per year in Oxford pro rata (181k population), probably more as it is the fourth most congested city in the UK in addition to the health effects described below
  • Headington has a score of educational institutions with vulnerable children and students, mostly lining the commuter routes to the hospitals
  • The vast car private car parking provision (4646) at the JR and Churchill Hospitals (and less so the NOC)  – 65-70% which is reserved for staff, dwarfs all other destination parking in the city
  • The generated trips would, by a reasonable calculation, be 74 miles of cars a day end to end
  • The draft local plan, based on it current status, will REMOVE the planning requirement to reduce or minimise parking both on these sites, and ALL others  in Oxford for any new development, asking only that the developer present a “travel plan” to the Oxford City Council
  • At  the hearing into the John Radcliffe Site Policy  on Weds Dec 11th the Trust again pushed its case for the ability to INCREASE parking on all its sites, in addition to the removal of the requirement to reduce parking
  • The State can not and must not endorse either this intent or formally accept that staff retention is an acceptable reason for damaging our planet, city and our children’s health
  • Staff pay £69-£345 a year for a parking permit based on income, incentivising car use
  • Visitor parking earns £2.3 million revenue for the Trust

The Parking Issue Explained

A total of 4646 car parking spaces exist as below [2] (see references at end), of which AT LEAST 61% are allocated to staff, but 71% is more realistic.

 Staff Informal Staff+Inf Visitor Total
JR 1581 250 1831 769 2600
Churchill 892 183 1075 431 1506
NOC 345 20 365 175 540
Totals 2818 453 3271 1375 4646
Percent 60.7% 9.8% 70.4% 29.6% 100.0%

**Most informal spaces will be used by staff as a visitor would not risk parking “informally”, therefore these are grouped together as staff+informal.

Informal parking places are a planning violation so seem illegal.

The OCC controlled parking spaces in the City Centre are shown below:

Name Car Spaces
Oxpens 179
Broadstreet 30 (Estimated)
Gloucester Green 105
Oxford Train 556
St Giles 200 (Estimated+other on street allowance)
Westgate 1000
Worcester 200
Total 2270

Put simply, the hospitals’ parking provision is over DOUBLE the entire Oxford City Council parking provision in the City. (4646/2270), the rest of Headington has only a 120 space car park in Old High Street, and St Leonard’s (47), and Old Road Campus (417+) and a few relatively minor car parks (eg: Headington School)

The BMW plant is located further away – It is hard to estimate BMW parking as some may be new cars and no figures are available.
Appendix 1 shows the flows in and out of the JR main entrance only at peak hours[5], this is equivalent to the entire traffic movements into Oxford on Marsh Lane, a major route into the city.

Appendix 2 shows the the sheer scale of parking as an aerial view.

To place this in perspective, assuming a 4m long Ford Fiesta, with 0.5m between it and the car in front, the cars going to the hospitals would form a queue 13 miles long:

(4646 * 4.5m)/1000 * 0.62=13m

Bad? It gets worse…

Each car making a two way trip would be 26 miles:

Bad? It gets worse…

Assume each staff park is used by three shifts, say 2.4 trips allowing for multiple day journeys by some staff = a further 26m  * 70% * 1.4 = 25m (1 trip already included,  2.4-1)

= 26m+25m=51m:

Bad? It gets worse…

If we further assume visitor parking would generate multiple trips, say 4 per day:

26m * 29.6% * 3 (4-1 trip included) = 23m+ 51m=74m

we can safely assume the total queues would be at least:

74 miles Of Small Cars Per Day

This is queue of cars from Headington to Central London and halfway back.

Bad? It gets worse…

Promotion of Park On Driveway Schemes By The Trust

The Trust actively promotes park on the driveway schemes oddly as part of its staff “Sustainable Travel Plan” [3] as below:

OTHER INITIATIVES FOR PARKING OFF SITE

You may want to consider renting a private parking space – you can search for drives for rent near to your working place

https://www.justpark.com/uk/parking/oxford/

The ratio of  staff to allocated parking (staff+informal) is given below:

Hospital Staff Staff Park Spaces Park/staff
JR 7796 1581 23.5%
Churchill 2493 892 43.1%
NOC 1034 345 35.3%
Totals 11323 2818 28.9%

New developments demand a 1:7 ratio maximum, that of the Churchill at nearly 1:2 is striking.

Suffer The Children

The major commuter routes of London Road, Headley Way, Marsh Lane, St Clements, and others, heavily used by children (both in and out of vehicles), are not only the most polluted and congested in the city, they are also home to a very large number of Schools, Universities, Colleges and nurseries in close proximity including:

    • St Andrews Primary
    • St Matthews Primary School, Marston
    • New Marston Primary
    • Headington School
    • Rye St Anthony
    • Cheney School
    • St Josephs School
    • Oxford Brookes University
    • Oxford International College (OIC)
schools
Schools and Universities On Commuter Routes

Air Pollution -Oxford Health Impacts

A recent report[9] has attempted to personalise the health impacts of air pollution by explaining the consequences of air pollution in particular cities using statistical analysis:

The aim of the project is to develop statements on the effects of air pollution on health outcomes that may be more familiar to the public or specific groups of the public than life years, life expectancy or numbers of deaths. [9,p.11]

The figures below must be treated with great caution as there are many confounding factors involved, for example, Headington is relatively spacious, but has almost permanent traffic jams, yet children walk along the commuter routes etc etc.

The figures a below are estimates for all of Oxford of which the Headington Hospitals contribute a substantial part only.

The statements below are therefore, by necessity, generalisations and extrapolate data from other studies – it must therefore be taken indicatively, not literally, further research is required, particularly in relation to local impacts which may be more or less.  Please refer to the report for more details.[9]

Heart Attack

The risk of out of hospital cardiac arrest in Oxford is 1.9% higher on high air pollution days than lower air pollution days (short-term).

Each year on average, higher air pollution days in Oxford are responsible for 6 more cardiac arrests outside hospital than lower air pollution days. (short-term).

Stroke

The risk of emergency hospitalisations for stroke in Oxford is 2.2% higher on high air pollution days than on lower air pollution days (short-term).

Living near a busy road in Oxford increases your risk of hospitalisation for stroke by 7.4% (short- term).

On high air pollution days in Oxford, there are on average 2 more hospital admissions for stroke each year than on lower air pollution days (short-term).

Lowering air pollution by 26.2% on high air pollution days in Oxford could save 2 hospital admissions for stroke each year (short-term/alternative).

Each year on average, higher air pollution days in Oxford can send up to 4 more people to hospital for stroke than lower air pollution days (short-term).

Asthma

In Oxford, your child is 3.5% more likely to be hospitalised for asthma on days with high NO2 pollution compared to days with lower air pollution (short-term).

In Oxford, an extra 1 child is hospitalised with asthma on days where air pollution is high compared to days where air pollution is low on average each year (short-term).

In Oxford, children with asthma are 0.2% more likely to experience asthma symptoms on high air pollution days than on lower pollution days (short-term).

On high air pollution days, 4 more children with asthma in Oxford experience asthma symptoms than on lower pollution days (short-term).

In Oxford, adults are 1.2% more likely to be hospitalised for asthma on days with high NO2 pollution compared to days with lower air pollution (short-term).

In Oxford, an extra 1 adult are taken to hospital with asthma on days of high air pollution compared to days with lower air pollution(short-term).

Stunted Lung Growth

Roadside air pollution in Oxford stunts lung growth in children by 14.1% (long-term).

Cutting air pollution in Oxford by one fifth would increase children’s lung capacity by around 2.8% (long-term).

Living near busy roads in Oxford may contribute to an 10.3% greater chance of reduced lung function in children (long-term).

Cutting air pollution in Oxford by one fifth would result in 77 less children with low lung function each year (long-term).

Refers to children aged 6-8.

Lung Cancer

Cutting air pollution in Oxford by one fifth would decrease lung cancer cases by around 6.0% (long- term).

Cutting air pollution in Oxford by one fifth would result in 28 less lung cancer cases each year (long- term).

Low Birthweight

Living near busy roads in Oxford may contribute to a 0.4% greater risk of babies being born underweight (long-term).

Cutting air pollution in Oxford by one fifth would decrease the risk of babies being born underweight by around 0.1% (long-term).

20% is an arbitrary number for a reduction in long-term NO2 concentrations. Babies born underweight refers to babies born at term with a birthweight less than 2,500g.

Cutting air pollution in Oxford by one fifth would result in 1 fewer baby born underweight each year (long-term).

The Current Local Plan

The current Local Plan examination is currently nearing completion with the Planning Inspectors deciding if the plan is “sound.”

Site And Housing Policy Changes

The relevant parts of the current Trust proposed planning policies  are shown below – strike out is text submitted originally by OCC and stuck down by the Inspectors following representations by the Trust and the Inspectors’ concerns over s106/CIL regulations.

Note that reduce/minimise parking is the current policy which will be removed.

Underline is agreed inserted text, red (author) is to draw the reader’s attention. (old/new site designation).

The Nuffield Hospital (NOC)  is not included for convenience as it is relatively small but has similar wording and issues as below.

Churchill Hospital SP8/SP20 

Development proposals must not prejudice bus access through the site. Improvements to public transport access will be required. The development will be expected to minimise car parking spaces on site. Applicants will be expected to demonstrate how the development mitigates against traffic impacts and maximises access by alternative means of transport. Mitigation measures will be required to ensure that proposals do not lead to increased parking pressure on nearby residential streets.

John Radcliffe SP23/SP42

Development proposals must not prejudice bus access through the site. Improvements to public transport access will be required, walking and cycling access and the reduction of car parking provision on site and should be set out within a transport assessment, travel plan and reflected in the agreed masterplanin accordance with Oxfordshire County Council’s Local Transport Plan.

Why Was Reduce Parking Removed?

The Inspectors demanded the removal of any phrase such as “reduce parking” or “minimise parking” [6] on ALL Oxford sites on the grounds that it is contrary to CIL regulations which state:

The Community Infrastructure Levy Regulations 2010 (CIL)

122.—(1) This regulation applies where a relevant determination is made which results in planning permission being granted for development.

(2) A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is—

(a) necessary to make the development acceptable in planning terms;

(b) directly related to the development; and

(c) fairly and reasonably related in scale and kind to the development.

This is puzzling, as both (a) and (c) are certainly met by any new development, and (b) is also clearly related where new development bringing in more staff and associated traffic must be counterbalanced by corresponding reductions elsewhere – other than cycling and walking all modes of transport impact the environment, particularly in Oxford were bus jams are common.

It is further perplexing that no previous Inspector has ever challenged this although it has been in the current Site and Housing Policy for nearly six years (Feb 2013).  Representations to review this at the hearing were refused.

Although this decision stripped the Council of all effective power to control parking provision in the city, it simply meekly surrendered with no attempt to argue its case –  probably as the Inspectors have had to make scores, if not hundreds of corrections to make the Local Plan sound, leaving it in too weak a position, due its incompetence, to argue.

Many of the OCC errors were the same as in 2016, and entirely unforced as these were pointed out prior to submission to the Planning Inspectorate.

“Mitigation”

The reference to mitigation (Churchill) above is troubling as it implies that adverse impacts are acceptable, they are NOT.

The wording of the Churchill Policy above to “mitigate …parking pressures on nearby streets” can be construed to mean an increase in onsite parking would be acceptable on the grounds it would stop street parking – as the area is now in a CPZ this is simply incorrect.

CIL contributions from Universities and Hospitals are near zero (£28 per metre square) compared to business rates of £144, therefore will not generate much income for mitigations such as promotion of alternative travel plans.

Development is Already Unacceptable – RE6 and RE7

In the new Local Plan RE6 (air Pollution) and RE7 Policies planning permission will only be granted if: (Policy RE7)[7]:

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 unacceptable unaddressed transport impacts affecting communities, occupiers, neighbours and the existing transport network; and

c) provides mitigation measures where necessary.

But:

The current situation is ALREADY unacceptable, logically therefore a reduction is necessary, not mitigation which implies increase

The Trust – The “Special Case” Debunked

The Trust refers to its “operational needs” and states visitor parking as a justification for not reducing its parking provision and actually having the ability to increase it.

Meetings seem to have taken place in private with no public record of the assertions made, contrary to basic principles of transparency.

We wrote previously about the severe problems of traffic and parking at OUH (The Trust) Headington sites, particularly at the John Radcliffe Hospital, which present additional risks to ill patients and compromise the quality of care provided. Long traffic queues to enter the John Radcliffe site are increasingly blocking local roads as well as the site. We thank the Inspectors and Council for the changes made to the Plan in recognition of these difficulties. Specifically, we note that the Council has complied with requests from the Inspectors to remove references to parking reduction (or minimisation) in site-specific policies. The Trust [2]

Essentially, It is absurd to suggest, as it seems to, that the solution to local congestion is to provide even more parking to the detriment of the rest of the city.
Many visitors are ill or upset and no one would wish any one in this position any other than the easiest journey possible, but this only applies to less than 30% of the parking provision.

It does not explain, why, if it is so concerned about patients and visitors, it does not simply allocate more parking from the staff 70% contingent to visitor parking

Perhaps, the answer is in:

The OUH needs to attract and retain specialised staff and provide them with flexible travel options [2]

The justification for staff parking by the Trust is out of hours work, site to site travel, and the need to travel long distances from locations with poor public transport due to the unaffordability of housing in Oxford and specialist staff.[2]

These concerns are not unreasonable, but only in a minority of cases different to any other employer in Oxford, the removal of most destination car parking would in itself stimulate good public or shared transport options – much of the traffic and journey times are caused by the hospitals themselves – staff are not stuck in traffic, they ARE to an extent, the traffic:
 The starting point must be that the current situation is unacceptable and must be rectified, rather than simply dump its staff retention problems on the community.
 The Trust has requested the Inspector to change the Trust site planning policies to below:[4]

Any increase to onsite parking should be considered as part of a site-specific operational assessment and seek to balance operational needs, space requirements, efficient use of land and where relevant, attracting/retaining staff at the hospital site. The emphasis being on minimizing the level of car dependency at the site, to those users that can be encouraged to alternative modes of travel.

In effect, the Trust wishes the State to explicitly to endorse staff attraction and retention of staff as justification for increasing car parking with the attendant damage by incorporating this in the Site Strategies, therefore receiving the sanction of the State, this CAN NOT be allowed to pass.Site Policy change requested by the Trust:

Recognising requirements for travel plans, specific wording could also include: “Where operational considerations require car parking provision to be reviewed onsite, the operational case for this will be demonstrated by the Trust in accordance with the comprehensive Transport Strategy for the Trust and accompanied by the site wide travel policies.”

This is an issue of pressing concern to local residents and the wider community, particularly in relation to the John Radcliffe site but also more generally to hospital sites in Headington. [3] – The Trust
The Trust correctly identifies that this is a major issue, but implies it is advantageous to the  community and acting in its interest, this is presumptuous.
A petition to increase parking provision was organised by a Marston Councillor which attracted 4000+ signatures, but those affected are in a much wider area.

The area devoted to car parking at the the hospitals is not only a health and climate catastrophe, but also a very inefficient use of land that could provide more key worker accommodation (as at Ivy Lane which will be redeveloped) which in turn would reduce the traffic issues.

The “Travel Plan”

The Inspectors suggest that “reduce parking” be replaced by an obligation that all developers formulate a Travel Plan[6] to be accepted by the OCC, this will form part of the Trust Masterplan.

This will be ineffective as:

  • The developer (in this case the Trust) produces it
  • OCC does not have the resources or expertise to validate it
  • It is not tested for soundness as per the Local Plan
  • The travel plan will be relegated to a planning condition (as opposed to a policy violation which would be a refusal) with no public comment
  • The OCC would be authorising a travel plan outside either the competence or jurisdiction, as this belongs properly to LHA (Oxfordshire County Council0 which would have no formal role.
  • Its identity is dubious and plans continually change over time

In the event of a planning appeal, it would be practically impossible to enforce as the plan would be open to interpretation and ambiguity, it is further puzzling that the original text that included reference to the Oxfordshire LTP4 transport plan, was removed as it did not form part of the examinable plan, yet a developer plan is considered acceptable.

To conclude – this would effectively transfer power to determine parking levels to the developer, away from OCC.

Again and again in the hearing Officers of the OCC asked Trust to engage in a dialogue to find solutions stating “our door is always open,” recognising that the best solution is dedication by all parties to resolving this awful situation, rather the Trust seems to have chosen of conflict and protection of its own perceived interests.

It is extremely hard to take the Trust Sustainability Travel Plan seriously as it:

  • Offers cheap permits to staff, providing an incentive to use cars
  • Seeks to INCREASE parking with repeated representations to the Council and the Planning Inspectors
  • Promotes Park on the Driveway plans prominently in its Sustainable Travel Plan
  • In contrast to Old Road Campus, which has closed its gravel car parks to fulfil the planning conditions, permits 453 apparently illegally parked cars in clear violation current planning permissions

It is risible to ask a member of staff to heed a Sustainable Travel Plan after being granted a parking permit or finding driveway rental space promoted by the Trust.

Parking Policies

The Trust does exclude many areas from parking permit eligibility, unfortunately most of these are in areas that a poorly paid member of staff could not afford to live in – these are essentially:

  • 1.5 miles around the sites
  • Most of Oxford city area reachable by buses < 40 minutes
  • An exclusion area around Thornhill and Water Eaton Park and Rides only
  • Abingdon Central

Further, it does facilitate car share schemes and some travel discounts.

Parking permits are cheap and based on salary banding from £69 to £345 – providing a clear financial incentive to use a car rather than buses.  £69 equates to 2.5 weeks of travel approx. (£4 return)

The Financial Incentive

The total income earnt by the Trust from visitor parking is shown below (for the last year available, not supplied)  FOI – [10]

Hospital Patient and Visitor Income Revenue per Park
John Radcliffe Hospital 730 £1,658,083.51 £2,271.35
Churchill Hospital 391 £503,055.17 £1,286.59
Nuffield Orthopaedic Centre 159 £224,799.08 £1,413.83
£2,385,937.76

Major Developments

The JR and other hospitals have a master plan for major development although the details are not clear at this point.

The cumulative effects of development in Oxford from all sources has not been quantified or addressed, but it is clear it will have additional serious negative effects, the current situation is untenable.

The Old Road Campus development (not the Trust) under the 2012 Planning Permission 12/02072/OUT increased staff by 1117 with a further increase of 148 car parking places, accommodated by imposing as CPZ on the poor Lye Valley and Churchill residents who, in effect, pay for private development.

The Trust has permitted 453 unofficial parking spots (illegal) to remain in contrast to Old Road Campus which has complied with its planning conditions:

On Monday 17 September 2018* the new multi-storey car park on the Old Road Campus is scheduled to open. To ensure that the University meets its obligations in regards to the City’s planning regulations, the gravel car parks in use currently will be closed at that time.

Failed Solutions

The Access to Headington scheme, whose only purpose appears to be to facilitate car access to the Headington Hospitals out of the public purse, has now gone from £7 million to £18 million and has achieved little.

Even the few improved cycleways are reachable only via dangerous and polluted sections, and therefore of little benefit.  In any case, this will not solve the main issue which is most staff are poorly paid and are obliged to live outside of the city, well beyond cycling distance.

Oxfordshire County Council  appear to be incapable, after decades, of producing nothing more than a new bus route on a narrow streets closely mirroring the Science Park route and an absurd proposal of charging £500 per parking place, (Connect Oxfordshire) which would simply mean 2.3 Million (£500 * 4646) diverted from the hard pressed NHS budgets with no coherent or formulated plan as to how this money would be disbursed to improve standards.[8]

Conclusion

The continued inability of the three main parties involved, the Trust (apparent unwillingness), Oxford City Council (powerlessness)  and Oxfordshire County Council (incompetence) as the Local Highway Authority, to derive effective solutions to this nightmare is deeply disappointing.

All parties must accept that this climate and health emergency must be addressed without delay or prevarication.

Currently the Trust has welcomed the removal of reduction of on site parking and is pressing for an increase, simply put, there seems little will to address this with the urgency and determination required, indeed it is disappointing to see such determination by the Trust directed to creating an environmentally destructive and health adverse policy rather than the reverse – surely at odds with its core mission to heal, or better prevent.

Richard Doll was one of the epidemiologists responsible for discovering the link between smoking and cancer who worked at the John Radcliffe where a building is named in his honour – we can only wonder at his thoughts about his former employers current position on air pollution?

We do not, at the time of writing, fully understand the effects of air pollution, levels considered safe a few years ago are now considered dangerous due to micro-particle content which reaches deep into the lungs, the onus of proof is on the authorities to prove that a given level is safe.

Some set store on electric vehicles, still far off, which also have a carbon footprint – the ore from Western Australia’s Pilbara open cut mines is sent to Japan, it is smelted to steel, moulded into car bodies and shipped across the world – each and every component and manufacturer will have a different story, but the overall picture is the same, there is much non-carbon neutral about an electric car.

A joined up strategy is required which would include:

  • Substantial reduction of car park provision, forcing modal shifts
  • Inclusion of all Park & Rides in exclusion zones as announced in 2017 to hospital staff
  • 24*7 buses to at least Park and Rides every 10 minutes
  • Removal of apparently illegal “informal” parking
  • Analysis of common routes, by analysis of staff postcodes, and provision of bus or other options
  • Possibility of allowing cars with 3-4 occupants to use bus lanes (hard to enforce, but used in Asia with some success) not perfect, but an improvement
  • Bye-laws banning Park on Driveway schemes
  • Moving of non-frontline staff to more sustainable locations

The argument that this is not affordable is nonsensical – the costs of NOT resolving this issue is far more to society as a whole – the question is not if a strategy will be cheaper but who pays

Oxford’s future is bleak unless we, as citizens speak out loudly and clearly and bring an end to this madness, and this must start with calling out the Trust for its poor citizenship, and lack of ethics.  

The Trust not uniquely to blame, nor the only party responsible for Headington’s traffic woes,  but its apparent refusal to engage actively in an immediate and urgent reduction strategy makes it culpable as the starting point must be a willingness to actively work towards a solution.

NONE of this is going to work without the will and sense of urgency required – so far apparently lacking from all parties involved.

 

Mark

Headington Heritage, A personal blog

Visit  : www.headingtonheritage.org.uk
Email: headingheritage@outlook.com

Follow me on Twitter: @headingheritage

Release: 21/12/19 Version 1.0

Acknowledgements

UK100.org (@UK200 for the link to the Heath Report [9] cited above.

References

[1] Royal College of Physicians. Every breath we take: the lifelong impact of air pollution. Report of a working party. London: RCP, 2016.

[2] Matter 6I Written Statement – John Radcliffe Hospital – Site SP42 – Oxford University Hospitals Foundation Trust

[3] Staff Sustainable Travel Information, OUH

[4] COM.11 – Statement of Common Ground – Oxford University Hospital NHS Trust

[5] TC5637 – Oxfordshire Country Council, (Access To Headington Survey) 

[6] ICB_Inspectors_2nd_Response_to_Oxford_re_Initial_questions_1.pdf [also Appendix]

[7] OCC.3_Suggested_modifications_to_Inspectors_following_IC.1C_and_IC.2A_.pdf [also Appendix]

[8] Connecting Oxfordshire, Oxfordshire County Council

[9]   Personalising the Health Impacts of Air Pollution: Interim Statistics Summary for a Selection of Statements, King’s College London,Dimitris Evangelopoulos, Klea Katsouyanni, Heather Walton and Martin Williams Environmental Research Group

[10] FOI – Trust Request – F19-2955

Appendix 1 – Peak Traffic Flows To The JR

JR – Peak AM Flows

JR – PM Peak Flows

Appendix 2 – Parking Places From Above

The vast areas devoted to car parking in a tightly constrained city can be seen below:

NHS_JR_North_use

JR – North

NHS_JR_Mid_use

JR – Mid Section

NHS_JR_South_use

JR – South

Old Road Campus, University of Oxford (not the Trust) and some Churchill hospital in south:

  • NHS_Old_Road_Campus_use

    Old Road Campus/Some Churchill Parking

    NHS_Churchill_South_use

    Churchill – South

Appendix 3

Source: Oxford Local Plan (2019)

Inspectors’ note concerning the Council’s response to the Inspectors’ Initial Questions and Comments (Set 1) (Questions 8 to 12)

Question 8: Car parking

We do not have any issues regarding Oxford City Council’s sustainable travel objectives, and there is no need for the Council to explain the background to these objectives. Rather, our point is that measures required by planning condition or s106 obligation should fairly and reasonably relate to the development for which planning permission is being sought. Whilst it may be reasonable, depending on circumstances, for the Council to seek no increase in parking in relation to the proposed development, it is not sound for the policy to also require a reduction in (or minimisation of) the existing levels of parking elsewhere on site, since this parking serves existing operations. Such an approach would not fairly and reasonably relate to the development being permitted, and would be contrary to the CIL Regulations governing s106 planning obligations, and to national policy. It should be added incidentally that the terms “reduction” and “minimised” are inconsistent with each other and do not explain what exactly is expected of a developer.

In addition, there is the question of whether the policy has regard to the reality of the site’s operational requirements. Just taking one site, John Radcliffe Hospital (Policy SP42) as an example, this is a site with acknowledged existing parking stress; only granting planning permission for new facilities if parking is reduced elsewhere on the site may not have regard to operational issues on site. (The policy incidentally cannot require measures “in accordance with the Local Transport Plan” in any case, since that is not part of the development plan and has not been examined.)

Those policies which appear to require parking reductions for existing development are Policies SP8, SP9, SP10, SP11, SP42, SP55, SP56 and SP63 together with a further set of policies which require parking on certain sites to be “minimised”: Policies SP20, SP21, SP22, SP23 and SP61. The reference to a reduction in parking, or for parking to be minimised, must be removed from all the policies referred to above.

There is also a lack of clarity over how no increase (or no net increase) in parking would actually work, which would create difficulties for development management staff in practice and could prove a bone of contention at appeal. We can think of four common scenarios which the policy and appendix do not clearly address. What would “no net increase” mean for example for new non- residential development on a new site? New non-residential development on a cleared redevelopment site which formerly had operational uses with parking? Non-residential redevelopment of an existing operational site with parking? Non-residential development as a floorspace expansion of an existing operation?

Neither the policy nor the Appendix have enough clarity and are thus ineffective.

However, there is a way forward. To ensure that requirements that are fairly and reasonably related to the development, to ensure that operational needs are properly recognised, and to ensure fairness and consistency of approach across all forms of non-residential development, whilst at the same time pursuing the Council’s wider sustainability objectives, we suggest that the travel plan should be a starting point. That is because it is capable of taking into account “whole site” issues, whilst having regard to the overall objective of controlling private parking and encouraging modal shift. The Council have been willing to suggest this in relation to Sites SP8, SP9 and SP10 and partly in Appendix 7.3 but consistency of approach is needed in the plan. We suggest that this approach should be taken to all development and that the “no net increase” approach (with further explanation as to what that means) should be applied to redevelopment sites. This would give a strong purpose to the travel plan requirement, enable proper attention to be given towards specific local conditions and operational requirements and impacts, and avoid the issues we refer to above. It would also obviate the need to have parking clauses within individual site policies.

Policy M3, Paragraph 5 would thus read:

The parking requirement for all non-residential development, whether expansions of floorspace on existing sites, the redevelopment of existing or cleared sites, or new non-residential development on new sites, will be determined in the light of the submitted Transport Assessment or Travel Plan, which must take into account the objectives of this Plan to promote and achieve a shift towards sustainable modes of travel. The presumption will be that vehicle parking will be kept to the minimum necessary to ensure the successful functioning of the development.

In the case of the redevelopment of an existing or previously cleared site, there should be no net increase in parking on the site from the previous level and the Council will seek a reduction where there is good accessibility to a range of facilities.

Where the proposal is for the expansion of an existing operation on an existing large site, a comprehensive travel plan should be submitted that looks at the development in the context of the whole site, and demonstrates that opportunities will be sought to enhance and promote more sustainable travel to and from the wider site. The travel plan will be kept under review to ensure that future opportunities to encourage a shift towards sustainable modes of travel are taken.

We propose that the Council take this on as a main modification. The relevant appendix would need to be altered to reflect the position.

Residential parking issues are covered in our other set of questions.

Appendix 4

Source: Oxford Local Plan (2019)

IC.1B___Inspectors__2nd_response_to_Oxford_re_Initial_Questions_1

Policy M3, Paragraph 5 would thus read:

The parking requirement for all non-residential development, whether expansions of floorspace on existing sites, the redevelopment of existing or cleared sites, or new non-residential development on new sites, will be determined in the light of the submitted Transport Assessment or Travel Plan, which must take into account the objectives of this Plan to promote and achieve a shift towards sustainable modes of travel. The presumption will be that vehicle parking will be kept to the minimum necessary to ensure the successful functioning of the development.

In the case of the redevelopment of an existing or previously cleared site, there should be no net increase in parking on the site from the previous level and the Council will seek a reduction where there is good accessibility to a range of facilities.

Where the proposal is for the expansion of an existing operation on an existing large site, a comprehensive travel plan should be submitted that looks at the development in the context of the whole site, and demonstrates that opportunities will be sought to enhance and promote more sustainable travel to and from the wider site. The travel plan will be kept under review to ensure that future opportunities to encourage a shift towards sustainable modes of travel are taken.

Appendix 5

Source: Oxford Local Plan (2019)

OCC.3_Suggested_modifications_to_Inspectors_following_IC.1C_and_IC.2A_.pdf[7]

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 unacceptable unaddressed transport impacts affecting communities, occupiers, neighbours and the existing transport network; and

c) provides mitigation measures where necessary.

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