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Members’ Services Office,

Town Hall Extension


PO Box 532
Manchester, M60 2LA
June 2019
Dear Carolyn,

This letter is Deansgate Ward Councillors’ response to proposals for 129 apartments and 345 sq m
of commercial space across two buildings on Great Ducie Street/Mirabel Street (Planning Application
122280/FO/2019) of which you’re the Case Officer. We object to the proposals on the following
grounds:
 The proposed development amounts to overdevelopment
 The proposed development is too tall and fails to meet the requirements of Core Strategy
Policy EN 2
 The proposed development would cause considerable overlooking and is not designed to give
privacy both to its residents and neighbours in accordance with Policy H1 of the Core Strategy
 The proposed development does not appropriately reflect the character of the area, failing
to adhere to Policy EN 1 of the Core Strategy
 The proposed development harms the setting of heritage assets and does not meet the
requirements of Policy CC 9
 The proposed development would strain local roads (failure to account for uber/Deliveroo in
the documents)
 The proposed development would harm the pedestrian environment on Breslyn Street
 The proposed development would promote crime and anti-social behaviour
 The proposed development does not address existing and future deficiencies in physical,
social and green infrastructure in accordance with Policy H1
 The proposed development does not provide any affordable housing and fails to meet Core
Strategy Policy H8

Overdevelopment
The proposed development’s 129 apartments on a site of 0.12ha amounts to overdevelopment on
this particular site and given its location. This site is small, between the Manchester Arena and
existing residences on Mirabel Street, and surrounded by railway arches. This area is tightly enclosed
on all sides and the relatively low-rise structure on the site currently and the open nature of part of
the site provide relief for this. The proposals are excessive for such a small site and would create
an overbearing amount of development in this area.

Height
The proposed development involves a building of up to 13 storeys and a building of 9 storeys. This
is too tall for the location. It does not accord with Policy EN 2 because it is not of excellent design
quality, it is not appropriately located, it fails to contribute positively to place making and it brings
significant regeneration disbenefits on the setting of previous regeneration on Mirabel Street. The
drawings and views show the grey massing rising above the heritage railway bridges, which are in
the process of restoration and intruding on the setting of the Cathedral and its conservation area
(see View 08 Victoria Street in the Design & Access Statement)—just 50 metres away.

Moreover, a distinctive stepping down from the Greengate Area in the City of Salford to the
Manchester Arena is evident (see View 01 Great Ducie Street /A56 for example). Indeed, the
Tempus Tower in the City of Manchester is part of this narrative, despite having been constructed
prior to the cluster, it now clearly plays this role. It is also stepped back from the dense part of the
Mirabel Street area and more appropriately positioned toward Trinity Way, where there is sufficient
room for the building to fit its setting.

The proposed development ‘stepping up’ in the middle of this narrative would harm the setting of
the heritage assets on Mirabel Street including the former Parcel Office, by setting them in a steep
canyon where their architecture cannot be enjoyed. This causes harm to the area’s setting and the
grey massing rising above the bridges, disrupting the stepping down effect from Greengate to the
Arena harms the unique, attractive and distinctive Manchester skyline and approach views.

Loss of privacy
The proposed development is significantly higher than the existing residential accommodation that
fronts Mirabel Street (namely the Bay Building) and Breslyn Street (Beaumont Building). This would
create significant overlooking from the proposed development into existing residents’ dwellings. Due
to the taller elements, differential heights, and proposed rooftop amenity space—this overlooking
would be from a high number of apartments and is likely to occur at all times of the day and night.
This results in a loss of privacy for existing residents—and indeed to future residents should the
proposed development go ahead—which does not accord with Policy H1.

The character of the area


It fails to complement the City’s existing building assets: it is a grey-clad building in a neighbourhood
where residential development is characterised principally by being of red brick and instead it more
closely aligns to the grey clad of the Arena and the colours of bridge. This palette particularly fails
to enhance both the heritage assets on Mirabel Street and the railway bridges themselves. This
does not accord with the existing character of the area and is highlighted by the Great Ducie Street
and Mirabel Street Elevations, and CGIs, in the Design and Access Statement.

Moreover, this building would fundamentally alter the character of existing residences on Mirabel
and Breslyn streets, which are lower in height and are appreciated from Great Ducie Street. The
proposed development significantly alters such a setting. Additionally, the current proposals suggest
a refuse space, service access, and parking entrance opposite existing residential accommodation,
harming their setting too.

The Design & Access Statement clearly states that the Tempus Tower also acts as a marker for the
intersection of Mirabel Street and Trinity Way. This development would confuse this articulation and
cause harm to the existing architectural narrative. Moreover, the development would terminate a
pleasant view of Manchester Cathedral’s tower from Trinity Way/Great Ducie Street (in part reflected
by View 07 in the Design and Access Statement).

Heritage assets
The proposed development causes harm to the setting of the Cathedral and its Conservation Area
– as demonstrated by the proposed views in the Design and Access statement and argued in relation
to the proposed development’s height and the character of the area above.

Moreover, it must be stressed that the former Parcel Office is a heritage asset, and the residential
development that has taken place on Mirabel Street was undertaken in a way that was
complementary and respectful to this heritage. These regeneration efforts would be undone and
harmed by the proposed development, which would severely detract from the setting of these
heritage assets due to the height, colour palette, massing, and lack of architectural detail of the
proposed development.

Policy CC 9 is clear that development should preserve or enhance heritage assets and proposed
developments must ensure complementarity of form—this is patently not the case with the proposed
development. The grey palette does not create a clear form when against the heritage railway
bridges, grey walls beneath said bridges, and the arena—creating an unpleasant grey mass as the
dominating narrative—and it also does not reflect or meld with existing red-brick heritage assets
and residential development on Mirabel Street.

Local roads
The proposed development during construction and upon completion and occupation would place
strain on local roads.

The transport statement does not reference taxis, private hire vehicles, food delivery, or shopping
deliveries.

Use of on-demand transport services like private hire vehicles such as Uber or taxis such as Gett
have increased dramatically in recent years across the UK, in Manchester, and we know in the city
centre too.

Additionally, as city centre residents and city centre Councillors, we know the significant change in
recent years towards increasing use of delivery services such as Deliveroo, UberEATS and online
shopping deliveries. Online shopping refers both to regular delivery of groceries, as well as clothing,
household goods and larger items like white goods and furniture. With 129 apartments, this would
have a significant impact on Breslyn Street and Mirabel Street particularly.

The proposed development includes no layby or parking space for these and results in a loss of
space currently used for these by other residences. Residents regularly complain about congestion
and these issues in relation to existing residences and businesses in the area, where the existing
surface car parking is in use.

Breslyn Street is very tight and narrow, with residents raising concerns about it in its current form.
Yet the proposed development suggests it is an appropriate street for service/maintenance access
and emergency exit routes. This is hugely inappropriate and would compound issues discussed
above. Indeed, there is an additional concern about the accessibility of emergency vehicles to both
the proposed development (eg combatting a fire on Breslyn Street façade of the proposed
development) and existing residences.
On Mirabel Street, the proposed development includes a parking entrance, and service/maintenance
access directly across from existing dwellings (which would cause noise, odour, and other nuisances)
and adding a dropped curb very close to the Breslyn Street/Mirabel Street junction. These proposals
would further add to existing traffic problems on Mirabel Street that residents have raised with us
as local Councillors and is not acceptable.

The transport statement does not reflect on these issues appropriately, and it is worth stressing it
does not reflect at all on issues of on-demand transportation and food/grocery deliveries as
discussed. The proposed development would increase traffic problems, causing undue harm.

Pedestrian environment
The proposed development would severely harm the pedestrian environment in the area in a
number of ways:
 The creation of a steep canyon enclosing Breslyn Street would harm the pedestrian
environment. This impacts on its pleasantness and on pedestrian safety. It reduces sightlines
along the street, promoting crime and reducing safety with respect to vehicles.
 The proposed development includes very narrow pavements, which are to some extent the
existing walkways but longer sightlines along Breslyn Street (particularly at the corners) and
existing car parks provide alternative safe routes. Breslyn Street as a pedestrian
thoroughfare, traffic route and surrounded by the proposed development on two sides would
not be safe.
 The pedestrian routes along Mirabel Street would be severed by another parking access point
in close proximity to an existing junction, creating a stressful experience for pedestrians and
more route conflicts where accidents can occur.

Promotion of crime and anti-social behaviour


By enclosing the narrow Breslyn Street on two sides with tall development, crime and antisocial
behaviour will be promoted, because Breslyn Street (particularly on its initial corner off Mirabel
Street) would become dark, with limited sightlines, and dark building massing adding to the feeling
of an unsafe, hidden away environment—which will promote crime.

Physical, social & green infrastructure


The proposed development does not contribute anything to the existing city centre community by
way of social or green infrastructure—despite this being a clear requirement of Policy H1 to account
for the need to address deficiencies where they exist or where they would exist as a result of the
proposed development.

The proposed development results in the loss of open space, which provides sightlines across
Breslyn Street/Mirabel Street and replaces it all with built form. There is no contribution to green
space, which residents feel is lacking in this neighbourhoods, and is needed now and in the future.
This refers to both on-site and off-site contributions to green infrastructure.

With respect to social infrastructure, there is no contribution to public amenity of services


which are lacking in this neighbourhood and given the limited development sites in the area,
will continue to be lacking in the future. Despite the relatively large scale residential
development proposed, there is no attempt to estimate social impact, or acknowledgement
of the future services needs of residents in the proposed development. The development would
clearly place additional pressure on already under-pressure public services (eg patients at local GPs)
with additional housing and yet does not acknowledge this or attempt to mitigate it, whilst providing
nothing for existing residents who will suffer harm from this development.

Affordable housing contribution


The importance of mixed communities is also stressed by Policy H1 of the Core Strategy, meeting
the needs of a diverse and growing Manchester population. The list of characteristics provided in
Policy H1 and is clearly not exhaustive and does not exclude those of different income groups as
part of its definition. In conjunction with policy H8 which requires that new development contributes
to the City-wide target of 20% of new housing provision, it is clear this proposed development does
not adhere to planning policy. The proposed scheme provides no on-site affordable housing units
and makes no off-site contribution—failing both policies in this regard.

The financial viability assessment does not demonstrate that it is viable to deliver only a proportion
of the 20% target, instead it provides weak argument that does not accord with national policy as
to why it should deliver 0%. The Viability Assessment tests the proposed development against a
market return 17.5%, which it claims is a reduced profit margin, but the 2019 Planning Practice
Guidance (para 018) allows for 15 to 20% gross development value to be considered a suitable
return. The assessment therefore understates the viability of the scheme and does so as a tool to
reduce potential for S106 or affordable housing contributions, despite the harm caused by the
proposed development due to failing to concord with Policy H1 (for mixed communities) and H8
(20% of the housing supplied to be affordable). The proposed development also does not meet the
remaining circumstances outlined in Policy H8 whereby intermediate or social rented housing would
be inappropriate.

Conclusion
On balance, we believe that this scheme’s harm outweighs its benefits, in accordance with the
National Planning Policy Framework and Manchester City Council’s adopted Core Strategy and it
should be rejected by Manchester City Council.

Yours sincerely,

Marcus, Joan & William