Tag Archives: essential infrastructure

Our comments on Oxford Local Plan 2036

Posted on by • Posted in consultation, Flooding, OFA, Planning • Tagged , , , , , , , , , , , ,

Oxford Local Plan 2036
“Oxford City Council is producing a new Local Plan for Oxford. The Local Plan is important because it will shape how Oxford develops.” (from the ‘Preferred Options’ document for the Plan, Oxford City Council). The Council called for comments and we wrote recently as follows:

We wish to submit the following comments in relation to the proposed Oxford Local Plan 2036. Our comments all relate to flood risk.

Overall we are satisfied that the City Council has adopted an appropriate strategic approach to development and flood risk in the city, with new development targeted towards areas least at risk from flooding. We welcome the recognition in the document that flooding is a significant risk for the city and that this needs to be managed.
 
On the specific sections relating to flooding in the Preferred Option, we would like to see reference to the need to actively maintain watercourses in the city so that they function freely during times of flooding. We’re surprised that the SFRA Decembrer 2016 makes no mention of the need for clearing of trash gates, and the removal of vegetation and fallen trees from streams and ditches. Riparian owners in the city need to be encouraged to maintain water courses.
 
On Option 38A we would prefer to see adoption of a policy which states that there will be no development of previously undeveloped land in flood zone 3b. As the SFRA notes, this is the position in the current Core Strategy and we see no argument for weakening this.The new plan does not designate greenfield sites in zone 3b for development.
We recognise that water compatible structures and essential infrastructure may, in exceptional circumstance, be permitted in zone 3b under the NPPF. But the Council’s recent attempts to argue that an extension to the Seacourt Park & Ride constituted ‘essential infrastructure’ caused the Oxford Flood Alliance considerable concern. While references to NPPF in the Council’s proposed Local Plan may appear to provide safeguards to the public, these are significantly weakened if the Council intends to ‘interpret’ NPPF along the lines argued for the P&R extension or similar. We believe the plan document needs to provide clarity on this.

 If Preferred Option 38A is adopted as proposed we wish to state for the record that we interpret this to mean that NPPF will be strictly applied. It is clear in Table 2 and 3 in this Guidance Note what ‘Water Compatible’ and ‘Essential Infrastructure’ mean. We are therefore interpreting the Council’s policy to mean what the NPPF guidance says it means. This does not include car parks.

In Option 56A we would like to see a reference to riparian owners responsibility to maintain water courses. Simply treating them as a design feature isn’t sufficient.

 

OFA Steering Group
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Seacourt P&R – Key Point 4: Oxford City’s Planning Strategy

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cs2

Within Oxford City Council’s main strategic planning document, the Core Strategy, Core Strategy 2 (CS2, see above) states:

‘Greenfield land will not be allocated for development if any part of the development would be on Flood Zone 3b.’ 

Our comment: The proposed site for the new car park is greenfield, and in functional Flood Zone 3b.

CS2 also says that ‘development will only be permitted on greenfield land if it is specifically allocated for that use in the [Oxford City Council’s] Local Development Framework’.

Our comment: This site is not so allocated.

Core Strategy 11 (CS11) says:

‘Planning permission will not be granted for any development in the functional flood plain (Flood Zone 3b) except water-compatible uses and essential infrastructure.’

Our comment: The proposed site is neither ‘water-compatible’ (a category intended for developments such as marinas), nor ‘essential infrastructure’ (which includes projects such as water treatment works, or roads which have to pass through a floodplain).

In our view the position could not be clearer – this proposal is, in fact, precisely the kind of development that the Council’s own strategic planning policy is there to prevent.