From today’s Oxford Mail online.
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:
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 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.
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 (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).
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.