OFAS and development

Development

People have suggested that the Oxford Flood Alleviation Scheme (OFAS, the Scheme) could lead to, or facilitate, new development in the flood plain, which would add to urbanisation and reduce the amount of open space in west and south Oxford.

OFAS is about reducing flood risk to existing properties, business and infrastructure. It is not being proposed with the goal of creating opportunities for future development. There are a few areas which would benefit from the scheme where some development or redevelopmentmight take place in future, subject to the normal planning approvals being obtained. But this is incidental to the flood scheme.

Osney Mead

One of the areas where it’s claimed development will be facilitated is Osney Mead. Oxford University has publicly said that it has aspirations to redevelop this area. It is an already developed site, hosting a large number of businesses currently facing risk of flooding.

The University are paying for an additional bund (and all associated costs) to be created along the western edge of Ferry Hinksey Rd. This additional feature will increase protection from flooding for businesses currently operating from Osney Mead, and has been taken on board by OFAS for this reason alone. Any redevelopment would be of a brownfield site. Proposals for redevelopment would have to go through the planning process, demonstrate consistency with the existing Local Plan, and show they do not increase flood risk.

Elsewhere

The main area in the flood plain that is not presently built on, but which will be protected by OFAS from flooding in future, is on the river (east) side of the Abingdon Road, south of the hotel and including University College sports ground and Cowmead allotments.

This area (about the size of Osney Mead) will be protected by a bund along its eastern edge. We understand it would be very difficult, and more costly, to put the bund closer to the road. But even with the current OFAS design there is no certainty that this land will be developed.Any plans to develop these sites would be subject to local planning permission, and while OFAS could make the conditions easier to meet, it does not follow that development will happen here.

The vast majority of the flood plain will continue to flood – and that will be essential for the Scheme to work as planned. Although the Scheme area, where changes will be made, does not occupy all the flood plain meadowland, these flood meadows are nevertheless an integral part of the scheme design and need to be able to flood as they do now.

There will be no change to the Green Belt around Oxford as a result of the construction of OFAS.

The open, green flood plain meadows will be no more open to development than they are now, indeed arguably the fact that they will now be part of a specific, designed and paid-for flood scheme will make development there much less, not more, likely.

And if, as intended, the scheme area is expertly managed for wildlife, by organisations such as the Freshwater Habitats Trust or BBOWT, as well as for recreation (including fishing), the greater its chance of resisting the threat of unscrupulous developers.

There are other recent posts relating to OFAS –

Clarifications and explanations

Gravel mining – Be careful what you wish for

An Oxfordshire gravel mine, 2018

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OFAS – clarifications and explanations

We’re aware that there are some misapprehensions around about the Oxford Flood Alleviation Scheme (OFAS). The items that follow aim to clarify some of these points. Where necessary we have sought answers from the Environment Agency to be sure our facts are as accurate as possible.  We’ll be adding to these points, so check back.

See also a later post on OFAS and development

And posts on gravel mining: Gravel mining – Be careful what you wish for and An Oxfordshire gravel mine, 2018

#1 Willow Walk

Misapprehension

“The proposed 60 metre bridge over the ‘channel’ in Willow Walk will destroy over one third of the Walk.”

Fact

The new bridge will continue from the existing Willow Walk track, just raised slightly higher, and will span 19 metres.

It is designed to take existing vehicles and future maintenance vehicles. It will meet cycleway and British Horse Society standards and be built for a 100-year life span.

Thirteen individual large trees (12 white willows and one ash) and part of two groups of smaller trees will be felled to install the new bridge over the new channel. Willow Walk is about 400m long and a stretch 170m long will be cleared in the middle of it. Once construction is complete 20 white willows (10 on each side of the path) will be planted to reinstate the avenue of trees.

#2 Monks Causeway

(called North Hinksey Causeway in the planning documents)

Misapprehension

“Monks’ Causeway to the Fishes will be no more.”

Fact

Both the formal public right of way (North Hinksey Causeway or Monks Causeway) and the informal right of way will be maintained near the Fishes pub. New footbridges will be installed on both to allow access across the new channel.

See Planning Statement: 4.3.3 Recreation and public access.

#3 Transport of excavated material

Misapprehension

“100,000 tons of gravel are planned for extraction and removal along the single track entry point for cyclists, pedestrians and cars for the rugby, archery and tennis clubs through North Hinksey Village. At 25 tons a truck that is 8000 journeys there and back.”

Fact

There are no plans to transport gravel or any other excavated material through North Hinksey village.

#4 Seacourt Stream

Misapprehension 

“The Seacourt Stream will be damaged as the new ‘channel’ takes the flow away. It will have the potential to become a weed choked and rat infested ditch running behind gardens and the garden of the Fishes pub.”

OFA Comment

The published map is, unfortunately, unclear. It makes it look as if what’s said above is indeed the case.

Correct version

The existing Seacourt Stream as it runs behind the gardens along North Hinksey Village and behind the Fishes will remain the main channel, there will be no change under normal conditions.

The new channel below Willow Walk is not a new first-stage channel, it is a flood relief channel (sometimes known as a swale) which will only come into play during a flood: thus it acts exactly like a second-stage channel for the Seacourt Stream but at a distance from it. The swale is raised compared to the Seacourt Stream so water will only enter the swale when levels get high in a flood. 

The Bulstake Stream is higher than the new swale, so there will be some back-flow from that stream into the swale, reaching about as far as Willow Walk (depending on conditions).

Sketch map to follow.

#5 Trees along North Hinksey Lane

“The Botley Road warehouses were allowed because of the tree cover to the view from North Hinksey Lane. These trees will now be removed.”

OFA Comment

We don’t know the planning history so can’t comment on that. 

As far as the present scheme is concerned it is true that the trees on the left bank (i.e. left as you go downstream) of Seacourt Stream in Hinksey Meadow would be removed – that’s in order to take as little of that meadow, with its special MG4 grassland, as possible, while still allowing a two-stage channel for flood relief. There’s been a lot of discussion about this and it seems the best compromise.

On the other hand the trees on the right bank of Seacourt Stream, beside North Hinksey Lane, will not be removed. 

In addition, new trees will be planted along the field boundary by the warehouses – and in the old paddock by the stone arch bridge on Willow Walk.

#6 Dredging 

“Please dredge and clear the rivers and streams which have not been dredged for 40 years”

OFA comment

Whilst dredging can be of some small benefit during normal flows, a river channel is simply not large enough to contain the high flows associated with extreme floods, even if it has been dredged. Dredging gives the impression that something useful’s being done but the reality is that it’d be largely fruitless here and certainly not enough to significantly reduce flooding from a major flood. Dredging’s not without its downsides either – for example, and not surprisingly, it seriously damages riverine ecosystems, especially when done repeatedly.

Dredging the Thames would not significantly reduce flood risk to Oxford. It’s also worth noting that surveying has shown that the River Thames bed is largely stable. Areas dredged deeper would soon silt up again. 

The low-gradient, slow-flowing, braided watercourses of the Oxford flood plain are particularly prone to silt up again quickly after dredging. Dredging would have to be done frequently to do anything at all and even then it would not answer. If it would we’d be all for it, but it won’t.

There are a few specific locations, mainly associated with bridges and culverts, where local silting does need to be dealt with (see #7 below).

#7 Flood plain outflow

“Please … unblock the outflow from the flood plain by the old Abingdon road”

OFA comment

We have been working for over 10 years to achieve just that. We have had considerable success – a new channel and weir at Towle’s Mill, large new culverts under the railway access road at Redbridge, removal of a redundant level crossing bridge, improvements at Munday’s bridge under the railway in Kennington, and clearance of  blocked culverts under the railway at Coldharbour. Certainly these together must have helped in low level flooding – but more is still needed for bigger floods. Climate change predictions suggest these will be more likely in future. 

OFAS in fact provides just such further measures. As a preliminary, a new culvert was installed (taking advantage of the line being closed anyway) under the mainline railway in 2016 – this will be brought into use as an integral part of OFAS. Still to come, OFAS proposes new large culverts under the southern bypass to pull water through the floodplain; the channel banks of Hinksey Drain will be widened right up to Munday’s bridge to increase capacity, and the channel under the bridge itself will be further cleared.

Together these will greatly improve the outflow from the flood plain.

#8 Trees

“The scheme will destroy up to 4000 trees, a fact hidden by the reference in the proposal to ‘groups of trees’ being removed”

We have consulted the EA on this.

The short answer is that the tree-planting proposal results in more woodland within the scheme after completion than at present.

The long answer is here.

Edit, 6 December 2018: there is now an update on trees and OFAS here.

#9 Two stage channel

Misapprehension

“The two stage channel makes very little difference and there are better options. “

OFA response

Modelling of the scheme, with the two stage channel south of Botley Rd down to Abingdon Rd bridge removed, was undertaken by the EA. This appears as Appendix Q in the planning documents. This shows that without the two stage channel, whilst water levels are reduced from the current conditions they do not reduce as much as with the two stage channel which helps improve flow through the flood plain. Without the two stage channel the levels could still cause flooding in Osney Mead, Osney Island, Earl and Duke St and in the area of offices just west of Seacourt Street (the Minns estate). In the scenario without the two stage channel water levels south of the Devil’s Backbone (footpath to South Hinksey) are lower than with the two stage channel due to the redistribution of flows, with more water passing down the River Thames and increasing flood risk in the New Hinksey area. The alternatives which have been suggested – putting more water into the Seacourt Stream where it leaves the Thames would add water to the area where flooding is happening and would make the situation worse. The option of more culverts under the Botley Rd would potentially help move water from the north side of the road into Hinksey Meadow and would reduce the scale of the channel modifications near the Minns Industrial Estate however this would not be as cost effective as the currently proposed scheme and would not reduce levels downstream of Willow Walk.

OFA believes the two stage channel is required for the scheme to work.

Secretary of State on Seacourt

Re Seacourt P&R extension application, we were informed on 9 March as follows:

“The Government remains committed to giving more power to councils and communities to make their own decisions on planning issues, and believe that planning decisions should be made at the local level wherever possible.  The call-in policy makes it clear that the power to call in a case will only be used very selectively. The Secretary of State has decided, having had regard to this policy, not to call in this application.  He is satisfied that the application should be determined at a local level.”

The Secretary of State in question is the Secretary of State for Communities and Local Government, Sajid Javid. Of course his decision is disappointing to us.  The Secretary of State in 1998/99 did call-in, and refuse, a very similar application on the same site. The guidance on not building in the flood plain has become much tighter since then, following Sir Michael Pitt’s report on the nation-wide floods of July 2007. The permission that Oxford City Council has given itself is contrary to both national (NPPF) and local planning policy.  Note that the Secretary of State has not in any sense approved the plans, he has merely not intervened, leaving the decision to the local council.

We believe the Council has pushed through a perverse decision, contrary to planning guidance and a very great deal of substantial and principled opposition from local residents and local organisations. We believe that the Council may come to regret its decision. We will continue to make that case.

Objecting to Seacourt P&R extension – our latest comments

 

We remain strongly opposed to the planning application by Oxford City Council to extend its Seacourt Park and Ride into Oxford’s vital flood plain. There has been a nibble, nibble attrition of the flood plain over many years leading to worse flooding. That the City Council should itself be seeking to extend a car park into the flood plain that protects our city is quite extraordinary.

Here are our latest comments:

OFA comments on FRA Nov 2017 Final

OFA comment on PS Addendum Nov 2017 Final

Redbridge vs. Seacourt P&R from south + Maps

Letter to EA 30 November 2017_final

Lime stabilization considerations Nov17

Another letter about Seacourt P&R

Our letter published in the Oxford Times, 29 December 2016

We wrote recently about Oxford City Council’s proposal to extend the Seacourt Park & Ride into the flood plain, providing 658 extra parking spaces.

Now we read that the very same council wishes to abolish 270 parking spaces at Redbridge in order to develop a recycling facility. The core argument put forward by the City Council to justify their proposal at Seacourt is that extra car parking is so badly needed that it should be allowed even though the expansion site is in Green Belt and functional floodplain, and despite the fact that it is clearly contrary to national planning guidance and could put vehicles and people at risk during a flood. The Redbridge plans now make nonsense of the special case being advanced for Seacourt.

If that is not enough, the budget for construction of an extension at Seacourt has recently doubled from about £2 million to £4.1 million. The City Council Executive Board papers for 15 December 2016 show projected net revenue from the Seacourt Park & Ride extension of £160,000 a year, and this relies on an increase in parking charges from £2 to £3 possibly starting in autumn 2017.

At this rate the investment would take more than 25 years to pay back. If this figure assumes that the car park remains fully operational and doesn’t ever flood, when in reality it will do so virtually every year causing closure and expensive maintenance, the payback time will be even longer than 25 years.

We are discussing our concerns with the City Council as we believe that their proposal is ill-conceived and unjustifiable and that it should be abandoned before any more money is spent.

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 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.