Telephone +44 (0)161 234 3235

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cllr.marcus.johns@manchester.gov.uk

Members’ Services Office,

Town Hall Extension, Manchester,
M2 5DB

Councillor Marcus Johns

Labour Member for Deansgate Ward 20th November 2018

Dear Jennifer,

Reference: 121252/FO/2018
I am writing to you in relation to the planning application referenced above, having examined
the plans as a Local Councillor for Deansgate Ward, in which the application is lodged. I would
like to strongly object to the development referenced above. In the rest of this letter, I outline
my reasons for my objections, which focus on the excessive height of the Proposed Development,
the harm to visual amenity, the overdevelopment proposed, the negative effects on residential
amenity in the area, the reduction in pedestrian comfort due to wind, the omissions of the
Transport Statement, and the insufficiencies of the demand analysis and socioeconomic
statement.

Height

The Proposed Development, at 55 storeys and 162 metres above ground level (according to the
Design and Access Statement and 165m AGL according to 3.2 of the Planning Statement) is too
tall for its location.

The Tall Buildings’ Policy, EN 2, of the Core Strategy clearly expresses that a building should
have regard of the neighbouring buildings and local area in general. This is important in this
case in two respects.

Firstly, with regard to the whole area, there is a clear narrative of buildings stepping down
away from the taller buildings along the railway viaduct (such as Liberty Heights and No 1
Cambridge St) to mid- and low- rise buildings that predominate the Macintosh Village area,
particularly along Hulme St, Chester St, and Lower Ormond St. These buildings create a grid-
based urban grain with a canyon effect created by the brick warehouses along these streets.
Along Hulme Street for example, the canyon sits between six and ten storeys above street level
on the side of the Proposed Development and up to nine storeys on the opposite side. The tight
urban grain, characterised by similarly high canyons along these streets is an important
characteristic of the area. In this respect, the Proposed Development does not have regard for
its neighbouring buildings.

Secondly, there is an emerging cluster of taller buildings to the north of the Proposed
Development towards the railway viaduct. The Applicant acknowledges this 3.10 of the
Planning Statement, referring to “an emerging tall building cluster… forming in this part of
Manchester City Centre.” The Townscape and Visual Impact Assessment claims that
developments in the immediate vicinity are of the same or similar scale to the Proposed
Development. This is patently untrue. The Proposed Development is significantly taller than
other tall buildings within the cluster. The Planning Statements cites tall developments within
the cluster:

 No.1 Cambridge Street, a 28-storey development, which at 83m AGL is just over half the
height of the Proposed Development (using the Planning Statement’s 165m AGL).
 The 1-5 New Wakefield Street development, currently under construction, will reach 31
storeys, and which at 93m AGL would stand at 56% of the height of the Proposed
Development.
 Liberty Heights, which is directly adjacent to the Site, is the tallest development in the
local bluster of taller buildings at 37 storeys, which at 109m is only 2/3s the height of the
Proposed Development.
 The Circle Square masterplan area is also referenced including buildings ranging from
14 to 36 storeys in height, the tallest of which is currently under construction and will
stand at 105m, or 64% of the height of the Proposed Development.

It is clear from the above comparisons that this building would not complement and is not
similar to the scale of the other buildings in the taller cluster that it references. It is clear that
the Applicant’s reasoning for deciding against a 65-storey building for the Site also holds true
for the Proposed Development, which is to say that “the difference between the height and other
surrounding buildings is substantial and does not read as a consolidated cluster. This has a
negative impact on long views, and is often dominating” (Table 3.1, the Planning Statement).

The Application does not adequately reflect on the location of the site at the periphery of the
taller building cluster that it references. The Proposed Development, stepping up significantly
from the height of other buildings in the local area, would significantly shift the weight of the
cluster in terms of height away from the existing tall buildings towards the lower buildings in
the Macintosh Village area, including the Quadrangle and the Holiday Inn on Oxford Road,
which step down from the cluster. This would fundamentally alter, and damage, the character
of the neighbourhood.

The height of the Proposed Development does not appropriately reflect the location of the Site.

Visual Amenity

The Proposed Development would severely impact the visual amenity of the local area, and due
to its excessive height, areas further afield. The NPPF (Paragraph 127) advises that decisions
should be visually attractive, create a strong sense of place, and be sympathetic to the local
area. The Proposed Development is visually oppressive and would dominate the sense of place
of Macintosh Village, distracting from its current characteristics. It should also be considered
in this vein that the Proposed Development can be seen from within the Whitworth Street
Conservation Area and, for context, the Site is within a shorter distance to the conservation
area than its proposed height.

The Great Marlborough Street (South West) and North East elevations are of particular concern
as they do not contain windows. These facades, though detailed with a grid pattern, would create
a sheer, brick-clad face that is oppressive and overbearing on the immediate vicinity of the Site
and in all views in which it can be seen, which due to the height of the development includes a
very large area. Despite the detailing, these two facades are essentially 165m blank walls. This

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is poor design and poor placemaking, contradicting Policy EN 2 of the Core Strategy with respect
to excellent design quality and contribution to placemaking.

The Proposed Development substantially detracts from the visual amenity of the local area and
the wider City Centre.

Overdevelopment

The Proposed Development amounts to overdevelopment. The intensity of the development,

which provides 850 purpose-built student accommodation (PBSA) units is excessive. It would
fundamentally impact the amenity and character of the Macintosh Village area and place a
large amount of demand on local infrastructure and services.

This is particularly important in the case of impact on healthcare facilities, the Environmental
Statement identifies the adverse impact of the 850 units. It concludes, without assessment of
capacity levels at local healthcare facilities (nominally due to the difficulties in accessing data)
that this is minor and therefore does not require mitigation. The lack of forthcoming mitigation
from the developer ensures that this is simply another adverse impact of the Proposed
Development, clearly harmful to the public interest, that weighs on the side of refusal.

Policy CC 10 of the Core Strategy aims to ensure the City Centre appeals to a wide range of
residents and visitors. It particularly references increasing the diversity of activity in the City
Centre. The Proposed Development would concentrate further PBSA in the area. The
Application references a large number of existing and pipeline PBSA units in the vicinity. This
would tip the balance away from a mixed-use neighbourhood with residential communities,
commercial units, and PBSA, towards a neighbourhood dominated by PBSA, because of the high
number of units in the Proposed Development.

The provision of 850 PBSA units is considered to be overdevelopment, which would put strain
on local infrastructure (particularly healthcare facilities) and would significantly alter the
characteristics of the neighbourhood, reducing its attractiveness for residents.

Effects on residential properties

The Proposed Development would affect residential amenity by increasing noise and
disturbances. 850 residents would result in an increase in noise by virtue of increasing the
number of people and therefore the numbers of entries and exits of the building. This is
particularly pertinent of students, who generally will socialise in groups—often centred around
their accommodation—and use the night-time economy offer of the City Centre on a regular
basis, which is part of the draw for students looking to live in City Centre accommodation.

During construction, residents will be impacted by noise and vibrations at times. It must be
acknowledged that many residents do not work standard office hours, for example nurses and
paramedics, and therefore though working hours will be restricted, construction will have an
adverse effect at all times for some residents. Though the Planning Statement (5.70) does
acknowledge that there would be some impacts, it considers them minor. For residents living
nearby, the protracted and repetitive nature of noise from construction activity gives rise to a
negative impact, even if instances of loud noise are relatively brief.

The tall nature of the Proposed Development provides for significant overlooking of residents
living in the Macintosh Village area. This is a particular issue for those living in the Quadrangle

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building where balconies and roof terraces would be overlooked constantly by the Proposed
Development, with clear sightlines into their dwellings from some windows.

Wind

The Proposed Development would decrease pedestrian comfort and reduce public amenity in
the vicinity. Though the Wind Microclimate assessment finds an “acceptable” pedestrian safety
level and “in general, acceptable” pedestrian comfort, it finds a deterioration from the baseline,
with a reduced classification in terms of comfort criteria for the vast majority of locations tested,
even in the better-performing scenario which takes into account cumulative effects with respect
to other development. Though considered safe, the reduction in pedestrian comfort is another
negative impact on the public interest that would emanate from the Proposed Development.

Traffic

The Transport Statement does not adequately take into account the sharp increase in food
deliveries and shopping deliveries that is increasingly characterising city centre living. This is
particularly pertinent regarding the rise of platforms such as Deliveroo and Uber Eats for
example. The Statement refers to the “occasional” delivery, which does not seem to accord with
(i) the general experience of other PBSA developments or (ii) the 850 units, which will
accommodate at least 850 residents. The discussions of delivery and servicing focus solely on
the operations of the building management.

Moreover, the Transport Statement only references taxis with respect to the waiting rank on
the corner of Oxford Road and Whitworth Street West. In the days of apps like Uber and Gett,
taxis and private hire cars are a door-to-door offer, which are heavily utilised by students, of
which there would be at least 850 at the Proposed Development. This would also likely to be
activity concentrated in the evenings and weekends, related to the night time economy and
students going out.

Residents in the area already face issues with high levels of delivery-vehicle movements and
taxi movements at PBSA and student-dominated residences in the area. This would worsen
with the Proposed Developments’ 850 units, which makes no attempt at mitigating this. This
would also add to the noise and disturbance that existing residents would face upon the
occupation of the Proposed Development.

Demand Analysis

The argument which attempts to satisfy Policy H 12 of the Core Strategy by arguing there is
significant demand for the Proposed Development is not part of the universities’ redevelopment
plans nor is it being progressed in partnership with them. Due to the other negative impacts of
the Proposed Development, such as excessive height and harm to visual amenity, it also does
not meet regeneration priorities. Though the Applicant has made a case for demand, on balance,
its accordance with Policy H 12 is lacking and the benefits outlined do not outweigh the
substantial harm caused by the Proposed Development in other respects.

The Applicant attempts to claim in the Socioeconomic Impact Statement that the 850 residents
could increase expenditure in the local area by £6.4 million per annum and cites this as of major
beneficial significance. This claim makes no regard to the argument in Appendix B – PBSA
Need Case of the Planning Statement that demand for the PBSA would draw upon (i) those

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living in non-PBSA such as the Beetham Tower, (ii) those living in poor quality accommodation,
and (iii) the existing projected growth of universities.

It is clear from drawing these two arguments together, that the expenditure claimed by the
Applicant as a major benefit would be almost entirely displacement. The Applicant cannot
simultaneously argue in the Need Case the benefits with respect to freeing up non-PBSA for
other residents and that there would be £6.3m additional annual local expenditure from future
residents. Moreover, this claim suggests that the accommodation itself is the pull factor for
students coming to study in Manchester, rather than the Higher Education Institutions
themselves. The claims of economic benefits related to the Proposed Development are weak and
do not stand up to scrutiny. There are very few other compelling, public benefits that can be
considered with respect to the Proposed Development.

Use Class

The Application suggests that the Proposed Development as PBSA is within the Sui Generis
use class. However, the Proposed Development consists of 850 studios, which are self-contained
with kitchenettes and bathrooms. It is argued therefore that the use class is more in keeping
with a C3 (dwelling house) use class than Sui Generis, which has been seen in other Local
Planning Authorities. If the Proposed Development were considered C3, then Policy H 8 of the
Core Strategy should be considered as part of the determination of this Application.

In conclusion, I believe owing to the negative impacts of the Proposed Development outlined
above, that it should be refused. Therefore as a Councillor for Deansgate Ward, I object.

Yours sincerely,

Councillor Marcus Johns