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.
Entrance to the proposed site, 12 Feb 2016. There was not generalised flooding elsewhere, this area floods very early
North end of the proposed site, 12 Feb 2016
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