Application by Oxford City Council to extend Seacourt Park & Ride (Oxford City Planning application no. 16/02745/CT3).
We are strongly opposed to this application to build a car park extension right in the Oxford floodplain.
Our key points are:
Inappropriate development in the floodplain – contrary to Oxford City Council Core Strategy, CS2 – this is a greenfield site. It is also contrary to City Council Core Strategy 11 – it is neither ‘essential infrastructure’ nor ‘a water compatible structure’.
Not consistent with national planning policy framework (NPPF) guidelines.
Inappropriate development in the Green Belt.
A planning application for a similar scheme on the same site was rejected by the Secretary of State in 1999. Planning law has become tighter since.
County Transport Strategy envisages new P&R sites at Cumnor and Eynsham over the next few years; the present proposal is at variance with that. Traffic coming off the A34 and A420 may face increased delays in reaching the P&R.
Flood-risk assessment flawed:
- fails to note the serious floods since 2008
- does not properly consider the frequency with which this low lying site actually floods, which is often (it’s functional floodplain)
- permeable pavement recommended only slows run-off when flood event are so low risk it’s irrelevant. As soon as a significant flood event starts to develop the car park will be under water.
Emergency evacuation plan is inadequate and lacks detail. The site is at high risk of flooding, being 0.5-1 m lower than the existing car park. There is a significant risk to vehicles and people during a flood event: any emergency plan has to be very robust. Extra resources could be needed from already stretched emergency services. In a 1 in 100 flood the water would be 2m deep.
The ground is subject to movement and would require further investigation to see if remediable stabilisation would even work.
The site itself may be damaged by prolonged or severe flooding, even with surfaces broken and swept away. The fences proposed for the perimeter of the 2 ha site, and structures on the site, would be very vulnerable in a large scale flood.
The proposed permeable surface will be impaired by silt and other debris: it will require cleaning which may or may not restore its permeability. After prolonged flooding such paving may even have to be replaced (in early 2014 this site would have been under a significant depth of water for several months).
If fences, structures on the site, and cars were swept away they could end up blocking the nearby Seacourt which is a vital flood channel.
The proposal does not take proper account of the latest plans for the Oxford Flood Alleviation Scheme in this area.
The rationale for this extension being needed is that the present car park cannot be given a decking storey because of a covenant on the land. No such covenant has been produced by the applicant and we cannot find one. What there is is a lease agreement, with could potentially be varied by negotiation with the landlord, which could make this whole scheme unnecessary.
Oxford is at risk of flooding. The principle of not building on greenfield sites in the floodplain must be adhered to.
These reasons are set out in more detail in the following documents submitted to the planning authority, Oxford City Council (links download pdfs).
We are working hard to get our message across to the decision makers and to other people who may wish to comment. If you agree with us that this development should not be allowed to go ahead please do say so via the Oxford City planning website or speak to your local City Councillor.