Network Rail’s planning application for track-raising

Network Rail (NR) has applied for planning permission in relation to its plan to raise a particularly low area of the mainline track to London, beneath and either side of the old Abingdon Road bridge (Redbridge) near Kennington, to reduce the risk of the line flooding. Doing only this would increase the risk of flooding to the west of the line by raising the height of what is already a dam to the free flow of flood water. So NR propose a new culvert beneath the railway to compensate for this.

We have no objection to this plan in principle, but it must be done properly to ensure that the flood risk to properties and roads is not increased. If the mitigating culvert is too big areas to the east would be affected, too small and those to the west would suffer.

NR then need to convince the planning authority that their proposal gets the balance right and does not increase anyone’s flood risk. This is done mainly by modelling of flood flows and levels and reporting the results as part of a Flood Risk Assessment (FRA) which is at the heart of the planning application. This was first submitted in February. We went over this with a fine-tooth comb and found gaps and serious inconsistencies in the data presented. We did not believe that the document allowed the necessary judgement to be made, indeed it raised more questions than it answered. We made a submission to the planning authority, Oxford City Council, suggesting that, on the available evidence, it would be unwise to allow the application. The FRA, our comments, and many other documents can be seen on the council’s planning website – application number 15/03703/FUL. Our comments: OFA comments on 15/03703/FUL – Construction of a culvert.

A revised FRA (Revision AO1) was tabled by NR on 25 February in response to comments made by the Environment Agency to them. Because of the timing this revision  did not deal with our questions. We submitted further comments on AO1, reiterating and expanding on key points, on 9 March. We again gave our opinion that the evidence presented in the FRA was such that it could not allow a safe and proper decision to be made. This submission: 15:03703:FUL OFA Comments on the revised FRA (revision AO1, Feb 2016) F

After making our second submission to the planners we met with representatives of NR and their advisers. They confirmed that there were indeed the errors we had drawn attention to, in both the original and AO1 revision of the FRA. They said they had identified the reason for these errors and explained this. We understand that they will be filing a further revision, plus an amended version of an associated document, GRIP3, which is referred to in the FRA.

We have discussed our concerns with the planning officer at the Council who has been helpful and attentive to our arguments. A decision on the application has now been deferred to allow time for the revised documents from NR to be reviewed by the public and by Council planning staff.

Postscript: we were later asked to review the maps associated with the FRA, to compare what the model suggested with what we know ‘on the ground’. Our comments: 15:03703:FUL – OFA Review of flood model maps.