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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Work to start on Seacourt P&R

Work begins soon on Seacourt P&R extension, which we opposed fiercely.

http://www.oxfordmail.co.uk/news/16362587.start-date-set-for-controversial-seacourt-park-and-ride-expansion/

 

 

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.

Seacourt P&R – Key Point 5: Green Belt

The proposal is inconsistent with both national and local Green Belt policy:

  • The site is in the Oxford Green Belt where the presumption is that development is inappropriate. Preservation of ‘openness’ is a key objective of Green Belt policy, The NPPF places great emphasis on it. Attempting to hide the development from view by landscaping does not constitute preserving openness.
  • The proposal will also clearly breach Oxford City’s own Core Strategy key policy CS4 for the protection of Green Belt land.

 

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.