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.

Seacourt P&R: Planning Review Committee meeting

Oxford City Council’s Planning Review Committee met last night to reconsider the application to extend Seacourt park and ride. This had previously been approved by West Area Planning Committee but a review had been requested by concerned councillors.

The review committee confirmed the previous decision.

There is a report in the Oxford Mail.

We believe this decision is a huge mistake and we are disturbed by aspects of the decision-making process.

There is no lack of parking spaces here, nor overall. Should it ever be needed, better usage of existing parking could easily be achieved by live signage on the ring road. We have collected online data and visited the site over the very busy pre and post Christmas periods – the existing car park has never once been full. Opening of the new Westgate has not caused problems and many people clearly choose to drive into the city rather then use park and ride.

The cost is huge, £4.1 million is already budgeted. And there are many other urgent calls on the public purse. People are homeless and sleeping on the streets just a mile away.

The site floods from groundwater – an aspect that has received scant attention, despite our highlighting it repeatedly. Because of groundwater flooding there will be a net loss of floodplain if this development goes ahead. The site will also flood when the rivers flood. This will make it expensive to pump out, maintain and repair.

The decision is undoubtedly contrary to national planning guidance (NPPF) which is there to protect the floodplain and Green Belt. A previous extremely similar application on the site was the subject of a Planning Enquiry in 1998 and refused by the Secretary of State in 1999. Since 2007 the guidance has been strengthened following the Pitt Report on the Oxford and nation-wide flooding in 2007.

It is possible that the present application will be Called-in by the present Secretary of State for Communities and Local Government, Sajid Javid:  we have requested, jointly with Layla Moran MP, that this should happen. If the application is Called-in a Public Enquiry will follow. The reason for our request is that a decision to develop a car park in the floodplain sets a serious national precedent. Building in the floodplain is deplorable, except in the most exceptional cases – which this most certainly is not.

If the extension does eventually go ahead it is not impossible that the Council will in time come to regret it – as construction costs rise, maintenance is expensive due to recurrent flooding (exacerbated by climate change) and occupancy is low. But that will be no comfort  – much better it should never happen in the first place.

 

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.

 

 

“Flood Update” update – Seacourt P&R

We have ‘A letter from the Oxford Flood Alliance (OFA)’ in the Autumn 2017 Oxford City ‘Flood Update’ which you may have received. In case you wondered why there was no comment by us on the planning application to extend Seacourt Park and Ride, we did include such comment in our letter but it was not published. It read as follows:

Seacourt Park & Ride

We have opposed the application by Oxford City Council to extend this P&R into the flood plain. The present application does not, in our view, show that flood risk will not be increased. We believe that a revised application will be advertised in the not too distant future and we will scrutinise this with care.

Revisions to the application have since appeared. You can find the application by going to https://www.oxford.gov.uk/info/20066/planning_applications/328/view_and_comment_on_planning_applications and searching for Seacourt. Ref. No. is 16/02745/CT3. The closing date for comments is 4 October 2017.

We are consulting with Oxford MPs Anneliese Dodds and Layla Moran on this. We believe that if this is allowed to go ahead in the functional floodplain, and being (we believe) contrary to the National Planning Policy Framework (NPPF), it would set a most dangerous national precedent.

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 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.

 

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

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.