From today’s Oxford Mail online.
Click table and images to enlarge.
Weekends are quieter in the park and rides than are weekdays. Nevertheless we collected today’s data. Some was not available, as shown. So we visited Redbridge and Seacourt at peak times and there were plenty of empty spaces as the photos show.
The site for the proposed extension of Seacourt Park and Ride is designated under the Oxford Biodiversity Action Plan (BAP) 2015-2020. This is ‘An overview of actions to support biodiversity in Oxford City Council’s own estate and operations.’ Under this plan the Seacourt proposed extension site is designated as
- a Conservation Target Area
- a Habitat of Principal Importance.
It’s important habitat for many species including several badger setts. But, before the matter has even been before a Planning Committee for a decision, the City Council has cleared the area over the last week or so. The pictures tell the story. What a sad disgrace.
EDIT: and this recent video by the Oxfordshire Badger Group
It’s easy to get lost in the long and complicated arguments over flooding and planning objections.
But one thing stands out, very, very clear, and very, very important:
There is no need to increase capacity at Seacourt P&R. Oxford has more than enough parking, including enough park and ride.
This is despite the opening of the new Westgate shopping area. If the parking isn’t needed then why does the Council want to spend over £4 million of your, public, money on it? Never mind that it will sit largely unused, and be subject to flooding, and expensive pumping out, maintenance and repair. No, we don’t understand it either.
We looked at online data two days ago, Monday 4 December, 3 weeks before Christmas. At the busiest time, 2pm, there were over 2,700 empty spaces, many in park and rides. Seacourt and nearby Redbridge had 538 empty spaces between them.
Click table to enlarge.
See also our letter to the Oxford Times
For more detail look at these reports:
We are very strongly opposed to the proposed extension by Oxford City Council of Seacourt Park and Ride on the Botley Road, which has been mentioned here before.
If you want to see our latest objections go to http://public.oxford.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=OFE2FHMFIAV00 where you can see not only ours but the serious objections from others too.
If that doesn’t take you there direct go via https://www.oxford.gov.uk/info/20066/planning_applications click ‘View and comment on planning applications’, twice, and then search for Seacourt or 16/02745/CT3.
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.
We have submitted a further comment (our third), this time on the proposed porous paving, to the planning authority today. You can download it here.
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.