Further comment on Network Rail’s planning application for track-raising

We submitted our comments on the latest revision (A02) of Network Rail’s flood risk assessment (FRA) for their planning application for track-raising yesterday.

The planning application is number 15/03703 and details can be found on Oxford City Council’s planning portal https://www.oxford.gov.uk/info/20066/planning_applications/328/view_and_comment_on_planning_applications

The application is going to West Area Planning Committee for determination on 3 May at 2 pm at the Town Hall.

See also our earlier post https://oxfordfloodalliance.org.uk/2016/03/28/network-rails-planning-application-for-track-raising/

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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.

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.

Community meets academia

On 4 November three of us participated in a workshop hosted by Oxford University’s School of Geography and the Environment. The other ten participants included representatives from Pickering flood group in North Yorkshire, from Flood Network, from CAG (Community Action Groups) Oxfordshire, academics from Oxford, Lausanne and London, and communicators.

The workshop focused on the ‘Environmental Competency Group’ concept developed by the Oxford academic team (Prof Sarah Whatmore and Dr Catharina Landström) and exemplified in their working with the local community in Pickering in Yorkshire to develop a flood scheme.

Hydrological and hydraulic computer modelling of flooding are key tools in designing flood alleviation measures. We learnt about the importance of considering, and if needs be challenging, the assumptions underlying the modelling, and the possibility that the terms of reference given to consultant modellers may on occasion be rather restricted, meaning that potential alternatives could be missed. Nor is modelling a perfect process, the quality depending (of course) on the people doing the work. For these reasons independent scrutiny is important. While this could be by a another commercial consultant modelling team, review by academics can add further, expert and independent assurance to the process.

A further check would be a review of the model by community members to see, as far as possible, whether it matched local observations.

More generally we were able to set out how OFA has developed and worked over the past eight years. Likewise, we heard how the Pickering group had worked successfully, with help from the Oxford academic team. There was discussion of how such experience might be shared with others developing community flood groups.

The workshop was both interesting and useful: we thank the organisers and look forward to further collaboration in future.