Paul Butler Associates

Planning, Development & Heritage Consultants

30 January 2012 Daniela Ripa Trafford Council PO Box 96, Waterside House Sale Waterside Tatton Road Sale M33 7ZF

ldrss01 By post and email

Dear Ms Ripa Proposal: Location: Ref: Erection of 10-storey building to form 139 bedroom hotel and Old Trafford Supporters Club incorporating leisure, retail and assembly uses with associated servicing and landscaping Land at junction of Wharfside Way and Sir Matt Busby Way, Old Trafford 77866/FULL/2011

I write on behalf of Manchester United Limited (MUFC) regarding the above application. Whilst we recognise that the outline planning application (Ref: 75641/O/2010) approved in March 2011 established the principle of redeveloping the above Wharfside Way/Sir Matt Busby Way site, the development proposed by the current application differs significantly from the approved scheme. Although both schemes contain a mix of uses, the current application is dominated by hotel floorspace (3679.9sqm). The proposed assembly and leisure (1465.9sqm) and retail (90.8sqm) uses are ancillary to the main hotel use. As such, any relationship with the approved outline scheme is limited and the current application should thus be considered entirely on its own merit. This letter follows an appraisal of the planning application and its supporting documentation and considers the following issues: The relationship between Old Trafford Supporters Club (OTSC) and MUFC; The restriction of entry to OTSC members and their affiliates; Car, cycle and motorcycle parking; Highway safety; Design, scale and massing, and; MUFCs vision for the area surrounding Old Trafford football stadium. 1. The relationship between OTSC and MUFC Significant reference is made by the applicant to the relationship between OTSC and MUFC. This relationship is used to justify the applicants failure to fully appraise the proposed scheme against the provisions of Planning Policy Statement 4 (PPS4) Planning for Sustainable Economic Growth and to claim that any other location for the proposed scheme would be inappropriate.
31 Blackfriars Road, Salford, Manchester M3 7AQ t. 0161 835 3530 e. pba@paulbutlerassociates.co.uk w. www.paulbutlerassociates.co.uk
Company no. 3398456. Registered in England and Wales as Paul Butler Associates Ltd

Although OTSC is recognised by MUFC as an official supporters club, it is not part of MUFC. MUFC recognises in excess of 180 official supporters clubs worldwide and its relationship with OTSC is not therefore unique. Given that OTSCs affiliation with MUFC is limited, it is considered that this relationship is insufficient to justify the location of the proposed scheme without evidence that a sequential approach to site selection has been undertaken in accordance with PPS4 and Policy W2 Town Centres and Retail of the adopted Core Strategy. 2. Restriction of entry to OTSC members and affiliates MUFC were surprised to read that the Design and Access Statement suggests that the building and its facilities would be restricted to members of the OTSC and their affiliates and will not be open for use by the general public other than by prior agreement. The information that the club received on the proposals prior to the planning applications submission indicated that both the retail unit and hotel would be open to the public and indeed that this was fundamental to the economics of the proposal. The restriction of the building to private members (as well as the erroneous claim that the OTSC has links with MUFC above that of any of their other supporters clubs) has been used to justify the omission of a sequential exercise in accordance with PPS4. To be clear, as we understood it, the only part of the development that would be restricted to the OTSC was the clubroom all of the remainder of the building was to be open to the general public. The proposed schemes retail unit is clearly positioned at the buildings principal elevation to, presumably, attract passing trade. The unit is also only accessible from Sir Matt Busby Way and not from within the building itself. Due to the nature of the club and the composition of its supporters, and the location of the retail unit and its relationship with the rest of the proposed building, it is considered likely that the general public, as well as OTSC members and their affiliates, would be drawn to the unit. There is no information provided to explain how the general public would be deterred from entering the retail unit and/or making purchases. Again, we understood this to be fundamental to the economics of the plan. As such, it is considered that full details regarding the operation and management of the schemes retail unit should have been submitted. Limited details have also been submitted regarding the operation of the hotel element of the proposed scheme. Surprisingly, it is implied that the 139 hotel rooms will be occupied by OTSC members and their affiliates. MUFC understood the hotel to be positioned as entirely available to the general public. To our minds it is unlikely that any rooms will be occupied by OTSC members (on match days or non-match days) as, by definition, they live locally. Any planning condition or planning obligation imposed by the Council to limit the use of the hotel to OTSC members and their affiliates could be evaded by including a temporary OTSC membership with all room reservations in this case. Such a scenario could, in time, result in the establishment of an independent hotel use which would be unacceptable in this location and contrary to the provisions of PPS4 and local planning policy.

3. Car, cycle and motorcycle parking Policy L4 Sustainable Transport and Accessibility and Appendix 3: Car Parking Standards of the adopted Core Strategy set out the car parking space provision normally expected by the Council for development proposals within out-of-town locations such as this. Based on the floorspace and capacity figures listed within the planning application, 212 car parking spaces (139 for hotel staff/visitors, 5 for the retail unit and 68 for the assembly and leisure uses) should be provided by the proposed scheme in order to meet the Councils requirements. The proposed scheme does not include any on-site car parking provision. Whilst it is accepted that the application site is accessible by a variety of public transport modes, the scheme as proposed would be entirely reliant on car parking owned and operated by third parties, including MUFC and the Lowry Outlet Mall. MUFC acknowledge that confirmation was given in June 2010 that, subject to the clubs own business needs, up to 50 car parking spaces could be made available on the basis of a 6 month licence on commercial terms within the clubs visitor car parks following the redevelopment of the Wharfside Way/Sir Matt Busby Way site. It is understood that this confirmation was used to support the approved outline scheme. However commercial circumstances have changed since June 2010 and MUFC is no longer able to offer any designated spaces within its car parks. It is accepted that some OTSC members and their affiliates may already attend matches at the stadium and may park in MUFC-owned visitor car parks when attending these matches. As such, there would be no net change in car parking demand in the area surrounding the stadium if this group continued to park in MUFC-owned car parks on match days following the development of the proposed scheme. However, it is clear from the application submission that it would be possible for OTSC members and their affiliates not attending matches at the stadium to watch matches on screens in the assembly areas of the proposed development. Given that this group of members/affiliates may not have ordinarily travelled to the stadium area on a match day if the proposed development was not available for use, any parking spaces that they may unlawfully occupy in MUFC-owned car parks would result in a reduction of spaces available for legitimate spectators attending matches within the stadium. All MUFC-owned visitor car parks are closed and locked by MUFC staff approximately 2 hours after the end of each match. On non-match days, East Car Park E2 adjacent to Sir Matt Busby Way is open for use by stadium visitors, but is closed and locked at night. Overnight parking is not permitted on any MUFC-owned visitor car park. The overnight use of MUFCs car parks by the proposed hotels guests or the late night use of the proposed assembly areas would not therefore be possible. Although over 1800 car parking spaces are provided at the Lowry Outlet Mall, these spaces are also available to the shopping centres users and visitors to The Lowry, the Imperial War Museum North and the wider Salford Quays area. This car park is also over 1.5km from the application site and does not have 24 hour access. This considerable distance and restricted access limits the car parks usability and it is unlikely to be an attractive or feasible option to guests arriving at the proposed hotel with luggage or those who wish to have unrestricted access to their vehicle during their stay.

Detailed highway impact and traffic generation assessments should therefore be undertaken by the applicant to demonstrate how the proposed development would function given the unavailability of MUFCs visitor car parks and the unsuitability of the car parking at the Lowry Outlet Mall. Policy L4 and Appendix 3 of the adopted Core Strategy also sets out the cycle and motorcycle parking space provision normally expected by the Council for development proposals within outof-town locations. Based on the floorspace and capacity figures detailed within the planning application, 25 cycle parking spaces (14 for hotel staff/visitors, 2 for the retail unit and 9 for the assembly and leisure uses) and 11 motorcycle parking spaces (6 for hotel staff/visitors, 2 for the retail unit and 3 for the assembly and leisure uses) should be provided by the proposed scheme in order to meet the Councils requirements. Although significant reference is made by the applicant to the cycling infrastructure in the vicinity of the site, the proposed scheme makes no provision for on-site cycle storage for visitors or staff. The scheme also lacks any provision for motorcycle parking. Given that MUFCs existing cycle and motorcycle parking provision would not be available for use by the proposed development, full details of any alternative arrangements in place or detailed evidence to substantiate the reasons for failing to meet the Councils requirements should be submitted before the application can be determined. 4. Highway safety The close proximity of the entrance and exits of the proposed drop-off point to the traffic signals at the Wharfside Way/Sir Matt Busby Way junction could result in potential conflict arising between vehicles and pedestrians accessing the stadium along Sir Matt Busby Way and the users of the proposed scheme. The proposed removal of the left turn slip road onto Sir Matt Busby Way from Wharfside Way would further confuse priorities to the detriment of highway safety. 5. Design, scale and massing It is accepted that the proposed scheme has been designed with significant regard to the design and appearance of Old Trafford, however the applicants desire to create a tall landmark building in this location would obstruct key views towards the stadiums East Stand from Waters Reach, Wharfside Way and Trafford Wharf Road - thus failing to adhere to Policy L7 Design of the adopted Core Strategy. Due to the layout of the surrounding area; the orientation of the stadium; the location of the clubs megastore, and; its illuminated Manchester United signage, the East Stand is Old Traffords principal elevation and it forms a highly visible focal point for the majority of people approaching the stadium on both match and non-match days. Any development proposals which fail to acknowledge the stands significance as a consequence of inappropriate scale and massing should not therefore be accepted. 6. MUFCs vision for the area surrounding Old Trafford football stadium As part of their holistic vision for the continuing enhancement of the area surrounding the stadium, MUFC have a strategic plan which aims to guide the future redevelopment of their landholdings. This vision includes for works to the stadium itself as well as hospitality, conference, retail and visitor
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facilities. The provision of third party facilities such as those proposed by the planning application could undermine this comprehensive vision for the area to the detriment of its deliverability. Given the significant changes between the approved outline planning application and the proposed scheme, the current application should not be determined until additional information has been submitted to detail: how entry to the relevant parts of the building would be restricted to OTSC members and their affiliates at the relevant times; that a sequential approach to site selection has been undertaken given OTSCs limited affiliation with MUFC, and; how the proposed development would function given the unavailability of MUFCs visitor car parks and the unsuitability of the car parking at the Lowry Outlet Mall. However, and notwithstanding the submission of this additional information, MUFC shall continue to oppose and object to the proposed scheme due to: the impact of its scale and massing on views towards the stadiums principal East Stand elevation; the potential impact of the drop-off point and the removal of the left hand turn onto Sir Matt Busby Way on highway safety, and; the potential impact on the clubs holistic vision for the continuing enhancement of the area surrounding the stadium. For these reasons, it is clear that the proposed scheme fails to satisfy national and local planning guidance and should therefore be refused. I trust that you will give significant consideration to Manchester United Limiteds concerns during the determination of the planning application. If you have any questions or require any clarification, please do not hesitate to get in touch with me. Yours sincerely

Tom Flanagan MTCP MRTPI Director Cc George Johnstone, Manchester United Limited