Thoughts on OFAS

Why do we need a flood scheme at all?

We have had five major floods since 2000 and climate change will make things worse (indeed there is evidence from Oxford University that it already has). Oxford residents, and the economic well-being of the City, will suffer badly if something is not done. While the scheme will cause disruption during its construction it is imperative that Oxford is protected.

But what about downstream, won’t they be worse off?

All the detailed computer modelling for the Scheme (and we have recently heard on the grapevine that a totally independent consultancy has confirmed this ) says that flooding will not be made worse downstream. We know that comparisons are made with the Jubilee River – this scheme is nothing like that. Indeed OFAS is actually increasing the capacity of the floodplain, which together with bunding and rerouting of flow will reduce flood risk to many hundreds of properties.

Is it a concrete channel?

No, it isn’t. What it is is a much more naturalistic 2-stage channel, used around the world for flood relief.

How will the environment be affected?

While there will, regrettably, be some environmental losses, we are pressing hard – collaborating with the Environment Agency, and with support from others, particularly the Freshwater Habitats Trust – for environmental enhancements as part of the scheme. While one cannot compare one environmental loss directly with another environmental gain we believe the positives will be considerable.

Maintenance.

It’s so important that there is a plan now for the very long-term maintenance of the Scheme. In our experience over the last 10 years  “if maintenance can be neglected it probably will be”. There are some honourable exceptions and we certainly have we have no criticism whatever of the local EA maintenance team, who achieve a huge amount with very limited resources. Others do nothing or very little unless goaded and embarrassed into action. This Scheme, being “natural” will deteriorate quickly if not proactively maintained. The initial intent was to plan maintenance for 10 years: that is simply not good enough for such an expensive and important project. We have proposed that maintenance be planned for in perpetuity by setting up a responsible, funded, local body, maybe as a charitable trust (or similar).

A Green group

thinks that Oxford could and should be protected by very different means – while they are short on specifics, their main idea seems to be that planting enough trees upstream in the Cotswolds would solve Oxford’s problems. It wouldn’t. Expert opinion at our 2015 Symposium of Natural Flood Management (NFM)  made that very clear. Even afforesting the whole of the Cotswolds (not that that would ever happen) would not do the job. Oxford is simply too far downstream for that. That’s not to say that NFM can’t work in smaller catchments, nor that it might not make a contribution.

Flooding land upstream?

The Environment Agency’s Oxford Flood Risk Management Strategy (OFRMS) suggests this may be needed one day if climate change makes things sufficiently bad. Involving as it would temporary flooding large areas of farmland and other land it is never likely to be easy to implement.

 

 

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Seacourt P&R – Key Point 3: NPPF

 

National planning policy framework (NPPF) guidelines strongly recommend against the positioning of developments that are categorised (in this case according to the Environment Agency) as ‘less vulnerable’, in Flood Zone 3b, functional floodplain.

Sir Michael Pitt’s report on the severe and widespread summer floods of 2007 said there should be ‘a presumption against building in high flood risk areas in accordance with PPS25’ [now NPPF]  (Pitt Review; ‘Implementation and Delivery Guide, 2008: Final Recommendation 7). The guidance should be ‘kept under review and strengthened if and when necessary’ (Final Recommendation 8).

The title of Sir Michael Pitt’s report is ‘Learning Lessons from the 2007 Floods’. This development is far from being essential and NPPF should be adhered to. To do otherwise would set a very dangerous precedent.

See Key Point 1 and Key Point 2

Seacourt P&R – Key Point 2: Covenant, what covenant?

The Planning Statement for the application to extend Seacourt P&R states (para. 6.74):

” Consideration was given at an early stage in the design development to provision of a decked car park on the existing P&R site. This is not feasible because the existing P&R site is not within the Applicant’s freehold ownership and there is a legal covenant on the land which prohibits the construction of any buildings…”

That is to say, the rationale for an extension being needed, as opposed to raised decking on the existing car park, is that there is a covenant on the existing car park land which prevents the latter. We have asked the applicant if we can see the reported covenant but no such has been produced. Nor can we find one on searching the Land Registry. What we have been shown is an extract of what seems to be a form of lease agreement (not a covenant) on the existing car park. Such an agreement could potentially be varied by negotiation with the landlord.

See Key Point 1 and Key Point 3

Letter to the Oxford Times (8 Dec)

Letter from us published in the Oxford Times of 8 December 2016

The proposed extension to Seacourt Park & Ride is one of the worst planning proposals we’ve seen for some time. In 2013, after much public consultation, the City Council adopted a Core Strategy to guide development in the city over the next period. Core Strategy 2 includes the statement: “Greenfield land will not be allocated for development if any part of the development would be on Flood Zone 3b.” The proposed extension to the Park & Ride is a greenfield site in Flood Zone 3b, the functional flood plain. How can this be? The planning documents don’t explain. Although the documents include a review of relevant local policies, Core Strategy 2 mysteriously doesn’t get a mention. What’s driving the application is a worry about short-term problems with traffic congestion on the Botley Rd pending completion of new Park & Rides at Eynsham and Cumnor. How does this short-term need justify departing from core strategy? National planning policy is designed to encourage local authorities to take a strategic approach to planning, thereby avoiding the need for this kind of last minute quick-fix nibbling away at the floodplain.

Apart from the obvious conflict with planning policy, the application is riddled with errors. The Flood Risk Assessment says that the most recent flooding event at the site was 2008, ignoring the major disruption in the winter of 2012/13, and the serious floods in early 2014. The FRA completely fails to take account of the fact that the site floods frequently, and proposes a design which will quickly degrade as a results of flood damage and silting. There is serious risk in the event of a major flood of large sections of the car park breaking up and washing into the flood channel. It’s a nonsense and needs to be stopped.

Seacourt P&R – Key Point 1: a clash with OFAS?

 

The first image is a part of a plan, from the Environment Agency, of the proposed Oxford Flood Alleviation Scheme (OFAS) north of the Botley Road. This shows (as at 16 September 2016) that a key flood defence bund is planned for that scheme, running through the area where the car park extension is proposed.

The second image shows the area for the proposed extension to the Seacourt P&R.

It is not clear that the bund and the car park extension could co-exist. OFAS will reduce the risk of flooding in Oxford, vital for people and the future prosperity of the city, not least in the face of climate change. The car park extension proposal is flawed in many ways;  the plan should be dropped.

See Key Point 2 and Key Point 3

Seacourt P&R planning application vs. proposals for Redbridge P&R – comment

We have made further comments (our fourth) on the Seacourt P&R planning application to the Planning Officer today, 19 December 2016:

Planning Application 16/02745/CT3

We wrote to you earlier with regard to the validity of the so called ‘sequential test’ carried out for the Seacourt P&R extension. In addition to our previous argument about the existence of an option of negotiating with the landlord to erect decking on the current site, we have further grounds for objection to the ‘sequential test’.

The City Council Executive Board papers for 15 December 2016 include proposals for removing 270 parking spaces at Redbridge to accommodate a new waste transfer facility. It appears there is excess capacity at Redbridge P&R. The analysis of occupancy of Redbridge and Seacourt P&Rs included in the Executive Board papers, show that there is existing spare capacity at Redbridge, and but for the planned waste facility this could relieve Seacourt during the week. There is also capacity at both car parks sufficient to adsorb expected increases in weekend traffic once the Westend development completes.

The Planning Statement for the Seacourt extention makes no mention of the surplus capacity available at Redbridge. The review of Redbridge in the ‘sequential test’ simple says that there is limited scope to ‘expand’ Redbridge. This is deeply misleading. There is clearly scope to redirect surplus traffic from Seacourt to Redbridge, which might be achieved at no cost simply by use of differential pricing – i.e. making Seacourt more expensive. In the Seacourt application we’re told Seacourt has to expand because there isn’t an option at Redbridge. But the Redbridge proposal is using the possible expansion of Seacourt to justify closing parts of Redbridge. So the need to expand Seacourt is at least in part being created by the Council’s wish to re-purpose part of the Redbridge site. This is clearly an unacceptable justification for the Seacourt extending into the floodplain on Green Belt land.

Given the existence of sufficient capacity to deal with any increased weekend traffic related to the Westend, the arguments for the extension, contained in 3.20 of the Planning Statement, appear extremely general. Is this really the best justification the Council can offer for breaching its own core strategy, national policy on Green Belt, and guidance on development in the floodplain? The justification for this move appears to rely wholly on longer term projections about potential increases in traffic resulting from a growth in the city and county during the next 15 years. Such needs should be addressed through a strategic planning process.

We understand that the Council has to increasingly rely on the revenue it earns, and perhaps the real, unstated reason why this proposal has come forward is financial. But even this doesn’t make sense. The capital cost has now doubled from the original budget to £4.1m. Extra income from the extension, assuming rates increase from £2 to £3 a day, is projected at £160,000 a year according to the Executive Board papers. Even assuming this revenue is achievable the investment would take more than 26 years to pay back, and that is without discounting for the cost of capital. If, as we believe is likely, the site floods regularly, has to be closed part of the year, and faces significant maintenance costs, the payback period will be much longer.

This scheme is a nonsense and should not proceed.

Application by Oxford City Council to extend Seacourt Park & Ride

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).

  1. Our initial objections (28 Nov 2016)
  2. Further points (5 Dec 2016)
  3. Address to Council (5 Dec 2016)

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.

The Paris Agreement, December 2015

COP21Nearly 200 countries, developing and developed, and including oil and gas producers, reached agreement at the COP21 conference in Paris to address climate change. This looks like the beginning of the end for fossil fuels.

The deal requires that countries should stem greenhouse gas emissions, with the goal of peaking emissions as soon as possible and continuing the reductions as the century progresses. The aim is to keep global temperatures from rising more than 2°C by 2100, ideally keeping the rise below 1.5°C.

The deal will encourage trillions of dollars to be spent adapting to the effects of climate change – including of course flooding – and developing renewable energy. Developed countries are to send at least $100 billion each year to developing countries beginning in 2020.

The agreement gives countries leeway in determining how to cut their emissions but they must report how they are doing. Progress will be reviewed every five years.

Some elements, like reporting requirements, are legally binding, others, such as the setting of emissions targets for individual countries, are non-binding.

This is potentially a game-changing agreement and has been widely welcomed. Hopefully the catastrophic possibility of irreversible and escalating change can be averted. Nevertheless, climate change is here with us and we can expect to see its effects on weather patterns continuing for the foreseeable future, with increased flooding a prominent result.

Let us hope that the implementation of the Paris agreement is as good as promised.

Storm Desmond, flooding and climate change

corporation road carlisleCorporation Road, Carlisle (Photo: North News)

There has been widespread and severe flooding in Lancashire and Cumbria due to unprecedentedly heavy rainfall in a short period from Storm Desmond. One feels for the people affected, many not for the first time.

‘The 405mm of rain that fell in Thirlmere in the 38 hours to 8am on Sunday marked a record amount of rain ever to fall in a 48-hour period while the 341.4mm recorded at Honister Pass on Saturday broke the highest rainfall record for any 24-hour period.’

‘Dame Julia Slingo, the Met Office’s chief scientist, said the “extraordinary” conditions were likely the result of climate change. Her comments were echoed by Liz Truss, the Environment Secretary, who told MPs: “Climate change is factored into all the modelling work the Environment Agency does but clearly in the light of this extreme weather we are going to have a look at that modelling and make sure it’s fit for purpose.” ‘http://www.telegraph.co.uk/news/weather/12038356/Floods-caught-ministers-by-surprise.html

‘Prof Hall [Professor Jim Hall, director of the Environmental Change Institute at the University of Oxford] said there was always a trade off between costs and risks. Nevertheless, he added that the latest floods “should be a trigger for a revaluation of protection standards”.’ http://www.ft.com/cms/s/0/57b91e9c-9cf1-11e5-8ce1-f6219b685d74.html#axzz3tiucxtde

There is more on the relation between flooding and climate change here http://www.belfasttelegraph.co.uk/news/uk/heavy-rain-and-flooding-fit-with-climate-change-predictions-34268682.html

Extreme weather events associated with climate change are already more common: we need to make sure the assumptions used in the modelling of the Oxford Flood Alleviation Scheme (Oxford FAS) sufficiently take into account the effects of climate change.