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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NO NEED! Meeting to decide the Seacourt application today

NO NEED!

Two other posters which will be on display tonight

 

Meeting to decide the Seacourt application tomorrow – our posters for display

We will display these posters (and others) at the meeting of the Oxford City Council West Area Planning Committee to decide the Seacourt park and ride extension planning application, which (as you may have gathered by now) we oppose. The meeting is tomorrow evening (12 December) in the Assembly Room at the Town Hall and is open to the public; if you oppose the application please do attend. The meeting starts at 6pm and this will be the first application to be considered.

 

 

Meeting with Anneliese Dodds, MP for Oxford East

We met Anneliese Dodds, new MP for Oxford East earlier this week. We had a very useful discussion on a variety of flooding topics, including the Oxford Flood Alleviation Scheme, that we are going to be approaching local firms for financial support for the Scheme, our interest in environmental enhancement as part of the Scheme and in establishing a local body responsible for its maintenance in perpetuity.

We explained our serious reservations about the proposed extension of Seacourt P&R into the functional flood plain (Flood Zone 3b) and what we see as a flawed Flood Risk Assessment. Such an extension could not only affect flood risk itself but set a precedent which might lead to further encroachment onto the floodplain with potential further increase in flood risk. Anneliese will look at the revised planning application which is expected in due course.

We look forward to working with Anneliese in the future.

Our comments on Oxford Local Plan 2036

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

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

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.

Seacourt P&R – Key Point 3: NPPF

 

National planning policy framework (NPPF) guidelines strongly recommend against the positioning of developments that are categorised (in this case according to the Environment Agency) as ‘less vulnerable’, in Flood Zone 3b, functional floodplain.

Sir Michael Pitt’s report on the severe and widespread summer floods of 2007 said there should be ‘a presumption against building in high flood risk areas in accordance with PPS25’ [now NPPF]  (Pitt Review; ‘Implementation and Delivery Guide, 2008: Final Recommendation 7). The guidance should be ‘kept under review and strengthened if and when necessary’ (Final Recommendation 8).

The title of Sir Michael Pitt’s report is ‘Learning Lessons from the 2007 Floods’. This development is far from being essential and NPPF should be adhered to. To do otherwise would set a very dangerous precedent.

See Key Point 1 and Key Point 2