Postscript on Seacourt P&R extension

Members of OFA steering group, along with Councillor Colin Cook, and Stephanie Ouzman (a member of MP Layla Moran’s staff), met with Council officers and their consultants WYG on 27 April 2018 to try to obtain answers to a series of questions about the proposed Seacourt P&R extension. Subsequent to the meeting there was a further email exchange and answers were provided to a number of outstanding points by the Council. We appreciate having had this opportunity for dialogue about the issues, and now feel we understand what is being proposed.

It’s clear from the response from the Council that the planning documents did not provide a clear reference to the use of an impermeable membrane at the site. It wasn’t spelled out in the application, and the documents give no details of the tanking and how this would work. This has now been explained to us.

We believe we should have been able to get answers, as of right, on points of issue like this through the planning consultation. The fact that we couldn’t was a failure of the process, and below the standards we have observed in other applications locally. The County (LLFA), Environment Agency and planning officer didn’t, in our view, fully understand what WYG were proposing – this is clear from correspondence with them during and subsequent to the planning process. Councillors, therefore, approved a proposal which had information gaps in it on flood risk, and which they couldn’t have fully understood. In our view this happened because the planning outcome had already been pre-determined, and our queries were ignored because the process was designed to secure a particular outcome. 

Now that we know what’s actually proposed, we don’t believe (as far as we can judge) that the development poses an immediate and direct flood risk to local properties, which is obviously a welcome outcome. But all development in Flood Zone 3B by its very nature creates a risk to the consistent and predictable functioning of floodplains. Hence planning policy, which incorporates learning outcomes from decades of previous developments in areas subject to flooding, prohibits such developments because the medium and long-term consequences can be unexpected and far-reaching. 

We believe the development is inconsistent with planning guidelines – building in the floodplain and Green Belt – but recognise the planning officer advised otherwise, and that Councillors agreed with his interpretation. We regret that the Secretary of State did not choose to examine this issue, and believe the Council’s decision sets an unfortunate planning precedent. We also remain unconvinced of the need case.

The car park extension will be an additional source of pollution during a flood, and there is no way to stop this. This is undesirable, and a negative environmental impact. The Seacourt P&R extension is just to the north of OFAS which has an ‘environmental vision’ aiming to improve freshwater habitat – a vision the Council signed up to. 

If the development goes ahead, we’ll be watching with interest to see how often if floods and how the local authority deals with this. At times of flooding the car park will be a potential source of risk to users and members of the public. We will also continue to be vigilant about further planning applications brought forward by the Council, as the process has left us feeling we can’t rely on the local planning authority, or members of Council planning committees, to safeguard the public interest. We hope public concerns will be better addressed should any similar situation arise in future.

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Seacourt P&R – proposed extension

We are very strongly opposed to the proposed extension by Oxford City Council  of Seacourt Park and Ride on the Botley Road, which has been mentioned here before.

If you want to see our latest objections go to http://public.oxford.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=OFE2FHMFIAV00  where you can see not only ours but the serious objections from others too.

If that doesn’t take you there direct go via https://www.oxford.gov.uk/info/20066/planning_applications  click ‘View and comment on planning applications’, twice, and then search for Seacourt or 16/02745/CT3.

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

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.